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Overview
Sanctions and Export Controls Relief for Syria November 2025
The United States remains committed to supporting a stable, unified, and peaceful Syria. On May 13, 2025, President Trump announced the lifting of U.S. sanctions on Syria to give the country a chance at peace and prosperity. In June, the President issued Executive Order (E.O.) 14312,1 which formally removed U.S. sanctions and directed agencies to take additional measures, summarized below, to encourage U.S. private sector and foreign partner re- engagement in Syria. Removing U.S. sanctions will support Syria’s efforts to rebuild its economy, provide prosperity for all its citizens, including its ethnic and religious minorities, and combat terrorism.
What business with Syria is permissible?
• The United States no longer imposes comprehensive sanctions on Syria.
• The Caesar Act is suspended, except for sanctionable transactions with Russia...
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1) Overview of Syria-related sanctions state of play as of 11-10-25, issued concurrent with OFAC’s de-listing of “Muhammad al-Jawlani (Syrian President Ahmed al-Sharaa) and Syrian Interior Minister Anas Hasan Khattab from the Specially Designated Global Terrorist (SDGT) list” (concurrent with the UN resolution that did likewise with respect to the previously applicable UN sanctions, see https://www.fmprc.gov.cn/web//wjb_673085/zfxxgk_674865/gknrlb/jytz/202511/P020251108717331616075.pdf.
2) OFAC notes that Syria GL 25 remains in effect even after the removal of al-Sharaa and Khattab from the SDN List. As of 11-11-25, the only apparent use for the GL would be to authorize otherwise prohibited transactions involving HTS, which remains an SDN (still sanctioned by the UN) as of 11-11-25.
3) The Compliance Note announces what appears to be a full-scale suspension of the the...