THOMPSON COBURN TRADE ALERT | |
HEADLINE | Revocation of Sanctions on Syria |
DATE | July 2, 2025 |
AGENCY | Presidential Action; U.S. Department of State; U.S. Department of Treasury; Office of Foreign Assets Control |
EFFECTIVE DATES | July 1, 2025 |
BACKGROUND | In December 2024, Bashar al-Assad’s regime was ousted from Syria. On May 13, 2025, President Trump announced that he was “ordering the cessation of sanctions against Syria to give them a fresh start.” The following week, the Department of Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 25 to provide immediate sanctions relief for Syria from some (but not all) of the prohibitions. The President’s June 30, 2025 Executive Order now revokes most of the remaining sanctions on Syrian nationals and entities—including against the al-Nusra front—and authorizes the removal of most U.S. export controls on the country. |
DETAILS | On June 30, 2025, President Trump issued an Executive Order that: • Terminates the national emergency declared in 2004 due to the former regime of Bashar al-Assad in Syria and revoked six Executive Orders issued between 2004 and 2011 that imposed sanctions on the regime and those connected to it. • Waives—effective 20 days after the Secretary of State transmits its required report—the sanctions imposed on Syria under the CBW Act for the prior use of chemical weapons by the Assad regime. • Directs the Secretary of State to examine and decide whether to suspend the sanctions required under that Caesar Act. • Instructs the Department of State and OFAC to remove a number of individuals and entities from the SDN and other sanctions lists, and to modify the designations of other entities. Syria remains subject to U.S. export controls enforced by both the BIS and DDTC prohibiting all exports or reexports of items regulated under the EAR. The Order “supports the relaxation of export controls and other restrictions” to be taken by various agencies, like General License 25. At the same time, the Executive Order expanded the scope of the national emergency declared in 2019 by Executive Order 13894, imposing new sanctions on any person or entity connected to the Assad regime’s war crimes, human rights abuses, or the proliferation of narcotics trafficking networks. While the actions by relevant agencies and the recent Executive Order transition away from a sealed-off Syria, transactions and shipments to Syria continue to be regulated and may require authorization or specific licenses depending on the goods and services involved. |
BASIS | The Executive Order is pursuant to the President’s powers under: • The International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.), • the National Emergencies Act (50 U.S.C. 1601 et seq.) (NEA), • the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 (Public Law 108-175) (Syria Accountability Act), • the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (Public Law 102-182, title III) (CBW Act), • the Caesar Syria Civilian Protection Act of 2019, as amended (22 U.S.C. 8791 note) (Caesar Act), • the Illicit Captagon Trafficking Suppression Act of 2023 (Public Law 118-50, div. P), and • section 301 of title 3, United States Code. |
CITE | The Executive Order of June 30, 2025, revokes and terminates: • Executive Order 13338 of May 11, 2004 (Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria); • Executive Order 13399 of April 25, 2006 (Blocking Property of Additional Persons in Connection With the National Emergency With Respect to Syria); • Executive Order 13460 of February 13, 2008 (Blocking Property of Additional Persons in Connection With the National Emergency With Respect to Syria); • Executive Order 13572 of April 29, 2011 (Blocking Property of Certain Persons with Respect to Human Rights Abuses in Syria); • Executive Order 13573 of May 18, 2011 (Blocking Property of Senior Officials of the Government of Syria); and • Executive Order 13582 of August 17, 2011 (Blocking Property of the Government of Syria and Prohibiting Certain Transactions with Respect to Syria). The Executive Order of June 30, 2025, expanded the scope of: • Executive Order 13894 of October 14, 2019 (Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria), as amended in and relied on for additional steps taken in Executive Order 14142 of January 15, 2025 (Taking Additional Steps With Respect to the Situation in Syria) White House – Providing for the Revocation of Syria Sanctions – The White House Fed. Reg. – Federal Register: Providing for the Revocation of Syria Sanctions OFAC Press Release – Revocation of Syria Sanctions; Publication of Syria Frequently Asked Questions; Syria and Syria-related Designation Updates and Removals | Office of Foreign Assets Control. Department of State Fact Sheet – Termination of Syria Sanctions – United States Department of State Department of State Press Statement – Ending the Syria Sanctions Program for the Benefit of the Syrian People – United States Department of State |