Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria and Nov. 10, 2025 Caesar Act Waiver

Date issued: Nov. 11 2025

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TURBOFAC Commentary (211 words)

Notes:

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...