Syria OFAC Sanctions (SySR)

Syria OFAC sanctions under the Syrian Sanctions Regulations (SySR, 31 CFR Part 542) were among the most comprehensive U.S. sanctions programs, prohibiting most transactions involving Syria, Syrian government entities, and designated individuals and organizations. First imposed in 2004, the sanctions expanded significantly after 2011 in response to the Syrian civil war and human rights abuses by the Assad government. Note: the Assad regime fell in December 2024. On 30 June 2025 the United States issued Executive Order 14312, which revoked the Syria sanctions programme with effect from 1 July 2025; OFAC then removed the Syrian Sanctions Regulations, while list-based sanctions on Assad-era figures, terrorists and other designated persons remain. The description of the former programme below is kept for historical reference.

Former Syria Sanctions Programme: Prohibited Transactions and Exceptions (until 1 July 2025)

The table below and the sections that follow describe the programme as it stood before Executive Order 14312 ended it on 1 July 2025. These rules no longer apply to new transactions; list-based sanctions on designated persons remain. Check the current SDN List before any dealings.

Current position (2025–2026): OFAC renamed and amended the remaining Syria-related regulations in 31 C.F.R. Part 569 as the Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations, which continue sanctions on persons linked to atrocities, human-rights abuses and narcotics trafficking under the former regime (Federal Register, 25 September 2025). In the EU, economic sanctions on Syria were lifted in May 2025, while the Council extended the targeted asset freezes and travel bans on the former al-Assad regime until 1 June 2027 by a decision of 18 May 2026 (Thomson Reuters summary).

The origins of U.S. sanctions on Syria trace back to the early 2000s, amid heightened geopolitical tensions following the September 11th attacks. On May 11, 2004, President George W. Bush signed Executive Order 13338, marking the beginning of targeted sanctions against the Syrian government. 

Over the years, these sanctions expanded significantly, particularly in response to the Syrian civil war and human rights violations, until the Assad regime fell in December 2024 and the programme was revoked in 2025 (Executive Order 14312; see Thomson Reuters and Gibson Dunn summaries). The position has since changed repeatedly, so current list-based sanctions and export controls need to be checked case by case. Those who want to deal with Syria today should have experienced OFAC lawyers on their side to navigate legal requirements effectively.

Sanctions after the civil war

Following the outbreak of the Syrian civil war in 2011, the international community intensified its sanctions against Syria. The United States and the European Union were at the forefront, implementing measures to weaken the Assad regime’s ability to finance its military operations. These sanctions included:

The sanctions aimed to isolate the Syrian government economically and diplomatically, thereby compelling it to cease hostilities and negotiate a political settlement. Despite these efforts, the conflict persisted, leading to further sanctions and the inclusion of additional individuals and entities on sanctions lists.

Turkey–Syria earthquake in 2023 

The devastating earthquake that struck Turkey and Syria in February 2023 brought renewed attention to the impact of sanctions on humanitarian efforts. In the aftermath, there were widespread calls to lift or ease sanctions to facilitate relief operations. Critics argued that the sanctions were hindering the delivery of essential aid, while proponents maintained that humanitarian exemptions were in place to ensure aid could reach those in need.

In response, the United States issued Syria General License 23, temporarily authorizing transactions related to earthquake relief efforts. This license aimed to alleviate some of the logistical challenges faced by aid organizations operating in Syria. However, the exclusion of transactions involving petroleum and directly sanctioned entities limited the scope of the relief efforts.

The earthquake highlighted the ongoing debate over the balance between maintaining pressure on the Syrian regime and addressing the humanitarian needs of the Syrian population. As the situation evolves, the international community continues to grapple with the complexities of sanctions and their unintended consequences.

What Did the Former Syria Sanctions Target?

Restrictions on the Export or Supply of Certain Goods

Under the former OFAC Syria sanctions, there were stringent restrictions on the export or supply of specific goods to Syria. These measures were designed to limit the Syrian government’s access to resources that could be used to perpetuate conflict or human rights abuses. The prohibited items included:

• Arms and Related Materiel: This encompasses weapons, ammunition, military vehicles, and equipment, as well as spare parts and accessories. It also includes paramilitary equipment;
• Certain Equipment and Technology: Items related to the oil and gas sector, petrochemical industries, and new electricity power plants were restricted. This was to prevent the regime from bolstering its infrastructure that could support military operations;
• Communication Monitoring Tools: Equipment, technology, or software designed to monitor or intercept internet or telephone communications were banned to prevent surveillance and repression of the civilian population;
• Currency and Coinage: The supply of newly printed or unissued Syrian banknotes or coinage was prohibited to limit the regime’s financial capabilities;
• Luxury Goods: Certain luxury items were restricted to prevent the regime from accessing goods that could be used to reward loyalists or fund its activities;
• Materials and Chemicals: Certain materials, chemicals, micro-organisms, and toxins, along with equipment for processing these items, were banned, especially if they could be used for military purposes;
• Precious Metals and Gems: The supply of gold, precious metals, and diamonds was restricted, particularly if the recipient is the Syrian government or entities acting on its behalf.

These export restrictions were part of a broader strategy to isolate the Syrian regime economically and limit its ability to sustain its military efforts. By controlling the flow of critical goods, the sanctions aimed to pressure the government into complying with international demands for political reform and respect for human rights.

Restrictions on the Import, Purchase, or Transport of Certain Goods

The sanctions against Syria included strict prohibitions on the import, purchase, or transport of specific goods, primarily aimed at curtailing the financial resources available to the Syrian government. 

• crude oil and petroleum products;
• gold, precious metals, and diamonds.

Restrictions on Certain Commercial Activities

The Syria sanctions regime imposed extensive restrictions on various commercial activities, particularly those related to the petrochemical, oil and gas industries, and the financial sector. 

The following activities were prohibited under the former sanctions against Syria:

• Investment in the petrochemical industry: acquiring shares in, establishing joint ventures with, or providing credit to Syrian entities engaged in the petrochemical sector was prohibited. 
• Oil and gas sector: selling interests in commercial activities within the oil and gas industry to Syrian entities was banned. 
• Financial sector restrictions: Syrian financial institutions were prohibited from opening offices or purchasing shares in foreign banks. Similarly, foreign financial institutions were barred from establishing correspondent banking relationships with Syrian banks or opening branches in Syria.
• Construction and power plant projects: engaging in the construction or installation of new power plants for electricity production in Syria was restricted. 

Restrictions on Provision of Certain Services

To complement restrictions on the export and import of goods and certain commercial activities, the Syria sanctions regime also imposed limitations on the provision of services related to these sanctioned goods and activities. These restrictions were designed to prevent the Syrian government from gaining indirect support through services that could enhance its capabilities.

• services related to export-sanctioned goods: it was prohibited to provide services connected to the supply of goods that are restricted from export to Syria.
• financial services for import-sanctioned goods: Offering financial assistance or services related to the import of goods that are banned from being purchased or transported from Syria was prohibited.
• investment services: services that facilitate investment in sanctioned commercial activities, particularly in sectors like oil and gas, were restricted.
• military and surveillance services: providing services that support military activities or the manufacture, maintenance, or use of export-sanctioned goods was prohibited. This extended to services that could enhance the regime’s surveillance capabilities, such as those related to internet or telecommunications monitoring;
• services involving precious metals and gems: if provided to the Government of Syria or entities acting on its behalf, services related to the supply, sale, transfer, import, purchase, or transport of gold, precious metals, or diamonds were restricted.

Restrictions on Providing Assets to Designated Persons or Entities

Under the former Syria sanctions regulations, it was strictly prohibited to directly or indirectly provide assets to, or for the benefit of, any designated person or entity; for persons who remain designated, comparable prohibitions continue under the successor list-based sanctions. This included:

• Financial Assets: Offering funds, loans, or any form of financial assistance to designated individuals or organizations was banned. This measure was intended to cut off financial support that could be used to further the regime’s activities;
• Tangible and Intangible Assets: Supplying goods, property, or any other resources that could be converted into financial support for the designated parties was prohibited;
• Indirect Support: Even indirect provision of assets, such as through intermediaries or third parties, was restricted to prevent any circumvention of the sanctions.

Restrictions on Dealing with the Assets of Designated Persons or Entities

Under the former Syria sanctions regime, stringent measures prevented the use or management of assets owned or controlled by designated individuals or entities. These assets were effectively “frozen,” meaning they could not be accessed or utilized in any manner. For persons who remain designated, the freeze continues under the successor list-based sanctions. The prohibition on dealing with these assets included:

• Using, Selling, or Moving Assets: It was forbidden to engage in any transactions involving the assets of designated persons or entities. This included using, selling, transferring, or otherwise handling these assets;

• Facilitating Use by Others: Assisting or allowing another person to use or deal with the frozen assets was also prohibited. This ensured that the designated parties cannot indirectly access their resources through intermediaries;

Our team of lawyers specializes in removal from SDN list. We provide comprehensive legal support, evaluate the specific circumstances, prepare and submit detailed petitions to the Office of Foreign Assets Control (OFAC).

Travel Bans

Executive Order 13608 (2012) addressed foreign sanctions evaders with respect to Iran and Syria, including the suspension of their entry into the United States, and other measures targeted individuals identified as supporting the former Syrian regime. Entry restrictions are separate from OFAC’s asset-blocking and trade controls; check the current position with counsel before relying on any exemption.

Restrictions on Illegally Removed Cultural Property

The former Syria sanctions regime enforced United Nations Security Council Resolution 2199, which aims to protect cultural property that has been illegally removed from Syria. This resolution is part of a broader international effort to preserve Syria’s rich cultural heritage and prevent the illicit trade of artifacts that have been displaced due to conflict. Cultural property covered by these restrictions included items of archaeological, historical, cultural, rare scientific, or religious significance.

Former Syria General Licence Transactions

Despite the extensive restrictions imposed by U.S. sanctions on Syria, certain transactions were exempted, allowing for limited financial interactions with the Syrian economy. These exemptions were designed to align with U.S. foreign policy and national security interests, facilitating activities that support humanitarian and non-profit efforts.

Through the issuance of OFAC general licenses, U.S. persons and entities could engage in specific transactions without needing individual approval. These licenses permitted a range of activities, including:

For transactions not covered by a general license, individuals and organizations could apply for a specific OFAC license. That process involved demonstrating that the proposed activities were consistent with U.S. policy objectives and did not undermine the sanctions’ goals. Since the programme ended on 1 July 2025, no licence is needed for dealings that were prohibited only by the former programme, but dealings with persons who remain designated still require authorisation. 

Our team of skilled sanctions attorneys can provide assistance in obtaining the necessary OFAC licenses for conducting transactions with Syria.

Faced issues with Syria Sanctions?

Complexities of Syria sanctions can be challenging for individuals and businesses, especially when attempting to comply with the regulations set forth by the Office of Foreign Assets Control (OFAC).  If you are facing difficulties related to Syria sanctions, our experienced OFAC sanctions lawyers are here to help.

We have extensive expertise in dealing with OFAC regulations and can provide comprehensive assistance to ensure you comply with sanctions requirements. Contact us today to schedule a consultation.

Dr. Anatoliy Yarovyi

Senior Partner, Attorney-at-law (Certificate to practise law No. 701 dated 28.12.2009)

Senior Partner with 20 years of professional experience. Advises on OFAC and international sanctions, removal from sanctions lists including the SDN List, and unblocking of assets, as well as the related criminal-law, extradition and INTERPOL risks. PhD in Law; LL.M., Stanford University.

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+357 96 447475

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