Navigating U.S. Sanctions on Syria: A Tactical Compliance Guide
Published: June 22, 2025
IMPORTANT DISCLAIMER: For Informational Purposes Only: The information contained in this report is provided for general informational and educational purposes only and is not intended to be, and should not be construed as, legal, financial, investment, compliance, or professional advice. This document does not constitute a substitute for obtaining advice from a qualified professional, including legal counsel specializing in U.S. sanctions and export control laws. All information should be independently verified against official government sources.
Executive Summary: The New Landscape
On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License 25 (GL 25), fundamentally altering the sanctions landscape following the collapse of the Assad regime. This license, along with a 180-day waiver of the Caesar Act, authorizes most transactions previously prohibited. Concurrent legislative efforts in the U.S. Congress to fully repeal the Caesar Act signal a durable, bipartisan policy shift toward enabling Syria's economic reconstruction and reintegration.
This environment creates significant commercial and investment opportunities but is coupled with complex, high-stakes compliance requirements. While broad prohibitions are being lifted, critical restrictions related to export controls, counter-terrorism, and specific sanctioned individuals remain firmly in place. This guide provides a tactical framework for operating compliantly while mitigating legal, financial, and reputational risk.
1. Core Sanctions Architecture: What Is Authorized vs. Prohibited?
Understanding the precise boundaries of permissible activity is the first step. The situation is not a complete removal of sanctions, but rather a broad authorization with critical carve-outs.
A. AUTHORIZED Transactions (Green Lights under GL 25)
GL 25 is a broad, self-executing license. If your activity falls under its scope, you do not need to apply for a specific license from OFAC.
- General Commercial Activity: All transactions previously prohibited by the Syrian Sanctions Regulations (31 CFR part 542) are now authorized, unless they involve persons or property still blocked (see Part B). This includes:
- New Investment: Across most sectors, including energy, construction, agriculture, and infrastructure.
- Provision of Services: Financial, legal, consulting, technical, and engineering services to persons and entities in Syria.
- Petroleum Sector: The import, export, and dealing in petroleum or petroleum products of Syrian origin.
- Dealings with the New Syrian Government: Transactions with the "Government of Syria" as it exists on or after May 13, 2025, are authorized. This includes ministries and state agencies.
- Transactions with Specific, Previously-Blocked Entities: GL 25 contains an Annex listing specific Specially Designated Nationals (SDNs) with whom transactions are now authorized. This includes key entities like:
- Central Bank of Syria
- Commercial Bank of Syria
- Syrian Petroleum Company
- Banias Refinery Company
- Syrian Arab Airlines
- (See Appendix Part 2 for the full list)
B. PROHIBITED Transactions (Enduring Red Lights & High-Risk Areas)
Despite GL 25, significant prohibitions and risks remain. These are the critical areas for due diligence.
- Dealings with Remaining SDNs: GL 25 does not authorize transactions with any person or entity on the SDN List that is NOT listed in the GL 25 Annex. This includes many Assad-regime cronies, human rights abusers, and illicit finance networks.
- Previously Blocked Property: Property and interests in property that were blocked as of May 22, 2025, remain blocked. GL 25 does not retroactively unblock frozen assets.
- Prohibited Foreign Government Nexus: Transactions for or on behalf of the Governments of Russia, Iran, or North Korea are explicitly prohibited.
- U.S. Export Controls (EAR & ITAR): CRITICAL RISK. GL 25 provides sanctions relief from OFAC; it does not authorize the export or re-export of goods, software, or technology controlled by the Department of Commerce (Export Administration Regulations - EAR) or the Department of State (International Traffic in Arms Regulations - ITAR).
- Most items other than EAR99-designated food and medicine still require a license from the Bureau of Industry and Security (BIS), and the licensing policy is likely to remain one of denial or case-by-case review for sensitive items.
- Counter-Terrorism Prohibitions:
- Foreign Terrorist Organizations (FTOs): Dealings with designated FTOs like Hayat Tahrir al-Sham (HTS) are strictly prohibited. The organizational designation remains a critical prohibition, even while its leader is authorized for transactions under GL 25.
- Material Support: Providing "material support" to an FTO (e.g., funds, services, lodging) carries severe criminal liability under U.S. law (18 U.S.C. § 2339B).
2. The Tactical Compliance Playbook: A Step-by-Step Guide
To ensure compliance, implement the following four-step process for any Syria-related engagement.
Step 1: Rigorous Counterparty Screening
- Action: Screen every Syrian counterparty, partner, supplier, and customer against the latest version of the OFAC SDN List.
- Nuance:
- If the entity is on the SDN List, check if it is also listed in the Annex to GL 25.
- YES: The transaction is likely authorized. Proceed to Step 2.
- NO: The transaction is prohibited. STOP.
- If the entity is not on the SDN List, proceed to check for beneficial ownership.
- If the entity is on the SDN List, check if it is also listed in the Annex to GL 25.
- Beneficial Ownership (The 50% Rule): Check the ownership structure of your counterparty. If it is owned 50% or more, in aggregate, by one or more persons on the SDN List (who are not in the GL 25 Annex), the entity itself is considered blocked.
Step 2: Transaction-Level Due Diligence
- Action: Analyze the specific details of the proposed business.
- End Use & End User: What is the ultimate purpose of the goods, services, or investment? Who is the ultimate beneficiary?
- Export Control Check: Are you exporting any physical goods, software, or technology from the U.S. or by a U.S. person? If so, you must determine its Export Control Classification Number (ECCN) and verify licensing requirements with BIS. Do not assume GL 25 covers this.
- Prohibited Nexus Check: Does the transaction involve, directly or indirectly, any SDNs not on the GL 25 Annex, or any element of the Russian, Iranian, or North Korean governments?
Step 3: Financial Flow Analysis & De-Risking
- Action: Map the flow of funds. Any transaction that touches the U.S. financial system (i.e., is cleared in U.S. Dollars or involves a U.S. bank) falls under U.S. jurisdiction.
- Challenge: Even though GL 25 authorizes transactions with entities like the Central Bank of Syria, many international banks will remain highly risk-averse (a practice known as "de-risking") and may refuse to process transactions.
- Tactical Advice:
- Engage with your financial institution early and provide them with a full compliance due diligence package to give them comfort.
- Work with financial institutions that have experience in high-risk jurisdictions.
- Structure payments in non-USD currencies and through non-U.S. financial institutions only if the transaction has no other U.S. nexus (e.g., no U.S. persons, goods, or services involved).
- Maintain meticulous records justifying the purpose and legitimacy of every payment.
Step 4: Documentation & Record-Keeping
- Action: Create a defensible audit trail for every transaction.
- Best Practice: For each significant engagement, create a "Syria Transaction Compliance Memo" that includes:
- Date-stamped screening results for all counterparties against the SDN list.
- Cross-check against the GL 25 Annex.
- Analysis of the 50% rule.
- End-use and end-user verification.
- Confirmation of EAR/ITAR classification and license status.
- A citation to GL 25 as the basis for the transaction's authorization.
- Retain all records for a minimum of five years.
3. The Future Operating Model & Strategic Implications
A critical question for all stakeholders is whether U.S. infrastructure (companies, banks, USD) is required for business in Syria. The short answer is no, but the practical reality is more complex. The extent of U.S. involvement determines the compliance burden and has profound strategic implications.
| Scenario of Engagement | Operational Requirements | Strategic Implications |
|---|---|---|
| 1. U.S. Person/Entity is Involved | - All parties, including U.S. persons and their foreign partners, must fully comply with U.S. law (OFAC, EAR, ITAR, FTO Prohibitions). - Transactions are subject to direct U.S. jurisdiction and enforcement. |
For the USA: Maintains maximum oversight and control, ensuring activities align with U.S. foreign policy (e.g., preventing benefits to Russia/Iran). For U.S. Business: Provides a "compliance advantage" due to familiarity with U.S. law but may increase operational friction and cost. For Foreign/Local Partners: Requires adopting rigorous U.S.-style compliance, which can be a barrier to entry. |
| 2. No U.S. Entity, but USD is Used | - The transaction must clear through the U.S. financial system, subjecting it to OFAC jurisdiction. - U.S. correspondent banks will scrutinize and potentially block or reject any transaction that appears non-compliant. |
For the USA: The global dominance of the USD provides a powerful lever for indirect control and monitoring of Syria's economy, even without direct U.S. corporate presence. For All Businesses: Using USD creates a significant compliance choke-point. It is the highest-risk channel for non-U.S. entities. |
| 3. No U.S. Entity and No USD (e.g., EUR/AED transaction) | - Primary compliance concern shifts to avoiding secondary sanctions risk (e.g., under the Caesar Act). - Transaction remains outside direct U.S. jurisdiction unless there is a hidden U.S. nexus (e.g., U.S.-person involvement, U.S.-origin technology). |
For the USA: Achieves the geopolitical goal of enabling Syrian reconstruction via allied capital (Gulf, EU) while minimizing direct U.S. exposure. This cedes direct economic influence for broader strategic stability. For Foreign/Local Businesses: This is the most likely path for large-scale reconstruction. The repeal of the Caesar Act is the key that fully unlocks this channel. |
4. Forward-Looking Intelligence: Monitoring Risks & Future Trajectory
The situation is dynamic. Compliance is not a one-time check.
A. Regulatory & Political Monitoring
- OFAC: GL 25 can be amended or revoked at any time. Subscribe to OFAC's email updates.
- Caesar Act Waiver: The State Department's waiver is temporary (180 days). Its renewal is contingent on the new government's actions. Monitor State Department announcements closely as the expiration date approaches (approx. November 19, 2025).
- Political Developments: The U.S. government has stated that sanctions relief is conditioned on the interim government's performance on counter-terrorism, human rights, and breaking ties with malign actors. Monitor reports from credible sources (e.g., Washington Institute, International Crisis Group) on these developments.
B. Legislative & Policy Developments (The "WILL BE" State)
| Development / Proposal | Source Credibility & Key Proponents | Potential Impact on Business | Recommended Action |
|---|---|---|---|
| Full Repeal of the Caesar Act | Confirmed: Bipartisan Bill Introduced. (Sponsors: Sen. Shaheen [D-NH], Sen. Paul [R-KY]) | Would remove the primary threat of secondary sanctions on non-U.S. partners (e.g., banks, investors), dramatically de-risking the environment for international investment. | Track the progress of this bill on congress.gov. This is the single most important legislative development to monitor. |
| Removal of State Sponsor of Terrorism (SST) Designation | Credible Report (Unconfirmed): Reported by news outlets following executive branch statements. | Would remove significant legal barriers to a wider range of U.S. foreign assistance and would ease certain export control requirements. | Monitor official announcements from the U.S. Department of State for confirmation. |
| Codification of GL 25 into Law | Moderate: Discussions among Senate Banking staff, supported by some financial institutions. | Would make current authorizations permanent and less subject to sudden reversal, providing long-term investment security. | Track Senate Banking Committee hearings. Provide feedback through legal counsel or trade groups on the need for legislative certainty. |
| Conditional Relief / "Snap-Back" Provisions | High: Stated policy of the current administration; likely to be included in any legislative action. | Sanctions could be re-imposed quickly if the Syrian government fails to meet benchmarks. | Incorporate robust "Sanctions Snap-Back Termination Clauses" into all contracts. |
Appendix
This appendix provides a detailed reference of the legal and regulatory architecture of U.S. sanctions related to Syria. It summarizes the key Executive Orders, statutes, and regulations that form the basis of the sanctions program and lists entities identified for sanctions or sanctions relief in the source documents.
1: Foundational Legal & Regulatory Authorities
The U.S. sanctions program on Syria is built upon a layered framework of authorities issued by the President and Congress, and implemented by the Department of the Treasury.
A. Key Enabling Statutes
These Acts of Congress provide the President with the legal authority to impose economic sanctions.
International Emergency Economic Powers Act (IEEPA) (50 U.S.C. §§ 1701-1706):
- Function: This is the primary statute empowering the President to regulate international commerce after declaring a national emergency in response to an "unusual and extraordinary threat" to the U.S. national security, foreign policy, or economy that originates substantially outside the United States.
- Key Powers Granted: The President may investigate, regulate, or prohibit foreign exchange transactions; block (freeze) property and interests in property of foreign countries or their nationals; and direct or compel actions related to that property.
- Penalties: Authorizes significant civil and criminal penalties for violations. Civil penalties can exceed $377,000 per violation or twice the transaction value. Willful violations can lead to fines up to $1 million and imprisonment up to 20 years.
National Emergencies Act (NEA) (50 U.S.C. §§ 1601-1651):
- Function: Establishes the procedural framework for the President to declare, manage, and terminate a national emergency.
- Key Provisions: Requires the President to formally declare a national emergency, transmit the declaration to Congress, and publish it in the Federal Register. An emergency terminates automatically after one year unless the President formally renews it.
Caesar Syria Civilian Protection Act of 2019 (as part of NDAA for FY2020; extended by NDAA 2025):
- Function: A landmark statute imposing mandatory secondary sanctions on foreign persons who provide significant support to the Assad regime and its affiliates.
- Key Prohibitions (Section 7412): Mandates sanctions on foreign persons who knowingly:
- Provide significant financial, material, or technological support to the Government of Syria or its senior political figures.
- Transact with military contractors, mercenaries, or paramilitaries operating on behalf of Syria, Russia, or Iran in Syria.
- Sell or provide significant goods, services, or technology that facilitate Syria's domestic oil and gas production.
- Sell or provide military aircraft or spare parts to the Government of Syria.
- Provide significant construction or engineering services to the Government of Syria.
- Sunset Clause: The Act was set to expire in December 2024 but was renewed by the National Defense Authorization Act (NDAA) for 2025, extending it until December 31, 2029.
Iran Threat Reduction and Syria Human Rights Act of 2012 (Title VII):
- Function: Imposes sanctions specifically targeting human rights abuses and censorship in Syria.
- Key Provisions: Requires the President to impose sanctions on persons responsible for:
- Serious human rights abuses against Syrian citizens or their family members (Sec. 702).
- Transferring goods or technologies to Syria likely to be used for human rights abuses, including surveillance technology (Sec. 703).
- Engaging in censorship or repression of freedom of expression (Sec. 704).
B. Key Executive Orders (EOs)
These orders, issued by the President, declare the national emergency and specify the exact prohibitions and designation criteria. They are listed chronologically to show the evolution of the sanctions regime.
EO 13338 (May 11, 2004):
- Action: Declared the initial national emergency, finding Syria's support for terrorism, occupation of Lebanon, and pursuit of WMD an "unusual and extraordinary threat."
- Prohibitions: Banned the export of most U.S. goods (except food/medicine) and blocked the property of persons determined to be contributing to Syria's threatening activities.
EO 13572 (April 29, 2011):
- Action: Expanded the emergency to include human rights abuses against the Syrian people.
- Prohibitions: Blocked the property of persons responsible for or complicit in human rights abuses in Syria.
EO 13582 (August 17, 2011):
- Action: Significantly escalated sanctions in response to the regime's escalating violence.
- Prohibitions: Blocked the property of the entire Government of Syria. Prohibited new U.S. investment in Syria, the export of services to Syria, and transactions involving Syrian-origin petroleum.
EO 13606 (April 22, 2012):
- Action: Targeted the use of information and communications technology to commit human rights abuses.
- Prohibitions: Blocked the property of persons who operate or provide technology that facilitates computer or network disruption, monitoring, or tracking to assist in human rights abuses by the governments of Iran and Syria.
EO 13608 (May 1, 2012):
- Action: Created a new category of sanctions targeting sanctions evaders.
- Prohibitions: Authorized sanctions against foreign persons who have violated, or facilitated deceptive transactions to evade, U.S. sanctions with respect to Iran and Syria. These persons are placed on the Foreign Sanctions Evaders (FSE) List, not the SDN List.
EO 13894 (October 14, 2019):
- Action: Declared a new national emergency related to the situation in Syria, initially focusing on actions by Turkey in northeast Syria.
- Prohibitions: Authorized sanctions against persons responsible for actions threatening the peace, security, or stability of Syria or for serious human rights abuses.
C. Implementing Regulations & General Licenses
31 CFR Part 542 - Syrian Sanctions Regulations (SySR):
- Function: This is the body of regulations issued by OFAC to implement the prohibitions of the various EOs and statutes. It defines key terms and outlines the specific rules of compliance.
- Key Definitions for Compliance:
§ 542.308 Government of Syria: Broadly defined to include the state, any political subdivision, agency, or instrumentality (including the Central Bank), any entity owned or controlled by them, and any person acting on their behalf.§ 542.411 Entities owned by... (The 50% Rule): An entity is considered blocked if it is owned, directly or indirectly, 50% or more in the aggregate by one or more blocked persons. This is a cornerstone of due diligence.§ 542.206, § 542.207: These sections codify the prohibitions on new investment and the export of services by U.S. persons.
OFAC General License 25 (GL 25) (May 23, 2025):
- Function: The central document authorizing most activity in the post-Assad scenario. It is a broad, "self-executing" license.
- Key Authorizations:
- Authorizes all transactions previously prohibited by the SySR, unless they involve persons or property still blocked.
- Authorizes transactions with the post-May 13, 2025 Government of Syria.
- Authorizes transactions with a specific list of 28 blocked persons and entities detailed in its Annex.
- Key Prohibitions (What GL 25 does NOT authorize):
- Transactions with any SDN not listed in its Annex.
- The unblocking of property frozen before May 22, 2025.
- Transactions involving the governments of Russia, Iran, or North Korea.
2: Consolidated List of Entities & Individuals Under Sanction
The following lists are compiled from the provided source documents. It is critical to distinguish between entities that remain fully blocked and those with whom transactions are now authorized under GL 25.
A. Entities & Individuals Authorized for Transactions under the Annex of Syria General License 25
The following 28 persons, although previously designated, are now authorized for transactions by U.S. persons as of May 23, 2025, per the Annex to GL 25. They remain on the SDN List but are covered by this general license.
| Category | Entity/Individual Name |
|---|---|
| Individuals | AL-JAWLANI, Abu Muhammad KHATTAB, Anas Hasan |
| Government & Financial Institutions | CENTRAL BANK OF SYRIA COMMERCIAL BANK OF SYRIA REAL ESTATE BANK AGRICULTURAL COOPERATIVE BANK INDUSTRIAL BANK POPULAR CREDIT BANK SAVING BANK SYRIAN MINISTRY OF PETROLEUM AND MINERAL RESOURCES SYRIAN MINISTRY OF TOURISM |
| Energy & Petroleum Sector | SYTROL GENERAL PETROLEUM CORPORATION SYRIAN COMPANY FOR OIL TRANSPORT SYRIAN GAS COMPANY SYRIAN PETROLEUM COMPANY BANIAS REFINERY COMPANY HOMS REFINERY COMPANY PUBLIC ESTABLISHMENT FOR REFINING AND DISTRIBUTION |
| Transportation & Logistics | SYRIAN ARAB AIRLINES GENERAL DIRECTORATE OF SYRIAN PORTS LATTAKIA PORT GENERAL COMPANY SYRIAN CHAMBER OF SHIPPING SYRIAN GENERAL AUTHORITY FOR MARITIME TRANSPORT SYRIAN SHIPPING AGENCIES COMPANY TARTOUS PORT GENERAL COMPANY |
| Media & Hospitality | GENERAL ORGANIZATION OF RADIO AND TV FOUR SEASONS DAMASCUS |
B. Other Entities & Individuals Subject to Sanctions (Non-Annex SDNs)
This category includes persons designated under various authorities who are not listed in the GL 25 Annex. Transactions with these persons remain strictly prohibited. The SDN List is extensive and constantly updated; the following are illustrative examples from the source documents.
| Entity/Individual Name | Known For / Sanctions Context |
|---|---|
| Bashar al-Assad & Family/Enablers | The former Syrian president and his inner circle, sanctioned for corruption, human rights abuses, and supporting terrorism. Transactions remain prohibited. |
| Hayat Tahrir al-Sham (HTS) | Designated as a Foreign Terrorist Organization (FTO). Any transaction that provides "material support" to HTS is subject to criminal prosecution. This is separate from sanctions on its leader, al-Jawlani, who is covered by GL 25. The organizational designation remains a critical prohibition. |
| Taher al-Kayali & Khaldoun Hamieh | Identified by OFAC as key figures in the illicit Captagon drug trafficking network. Transactions remain prohibited. |
| Polymedics LLC & Letia Company | Previously blocked entities related to the Assad regime. While GL 21B authorized COVID-related transactions with them, they are not listed in the GL 25 Annex, meaning general commercial transactions remain prohibited. |
| Any entity 50% or more owned by non-Annex SDNs | The "50% Rule" applies. If an unlisted Syrian company is majority-owned by a crony of the former regime who remains on the SDN List, that company is also considered blocked. |
C. Vessels Implicated in Sanctionable Petroleum Shipments to Syria
The following non-exhaustive lists are derived from OFAC shipping advisories issued in 2018, 2019, and 2024. These vessels were identified as having engaged in conduct that creates sanctions risk (e.g., delivering oil to Syria). While inclusion on this advisory list is not a formal designation, many have since been added to the SDN list. All must be screened before any transaction.
Vessels Identified as Blocked Property on the SDN List (per 2024 Advisory):
| Ship Name | IMO Number | Notes |
|---|---|---|
| ALPHA GAS | 8817693 | Formerly JUNO GAS |
| DEVREZ | 9120994 | |
| FINIKIA | 9385233 | |
| JASMINE | 9105085 | |
| MARINA | 9005493 | |
| SAN COSMAS | 9274343 | Formerly LAODICEA |
| SINOPA | 9172038 | |
| SOBAR | 9221970 | |
| SOLAN | 9155808 | |
| SOURIA | 9274331 | |
| TOUR 2 | 9364112 | |
| YAZ | 9735323 |
Additional Vessels Previously Identified in Advisories (Status requires verification):
| Ship Name | IMO Number | Notes |
|---|---|---|
| ALEKSE | 8012114 | Formerly ALTERA 1 |
| KARAKUZ | 9621558 | Formerly ALMETYEVSK |
| ANHONA | 9354521 | Formerly ARAMIS |
| ARSOS M | 9313761 | |
| AZIZ TORLAK | 9558763 | |
| BASILIA | 9012305 | |
| CANDY | 9005479 | Formerly VENICE |
| DISTYA | 9087972 | Formerly DISTYA AKULA |
| DISTYA PUSHTI | 9179127 | |
| EFTYXIA GAS | 8813116 | |
| ENERGY GAS | 9034690 | |
| FELIX | 9003079 | Formerly G MUSE |
| GEM | 8919752 | Formerly GEMINI |
| GEROY ROSSII PYATNITSKIKH | 9673214 | |
| GOEAST | 7526924 | |
| GOLDEN SEA | 8800298 | |
| HELEN M | 9308223 | |
| KADER | 9080493 | |
| KORSARO | 9373137 | |
| LEVANTE | 9391139 | |
| MAESTRO | 8810700 | |
| MAGNUS | 9018464 | Formerly GVENOUR |
| MEDIA | 9377432 | Formerly MEDIATOR |
| MIURA | 9390903 | |
| SUNBEAM | 9340386 | Formerly MOTIVATOR |
| MR NAUTILUS | 9150767 | |
| OASIS 1 | 9465629 | |
| OCEAN 61 | 8870865 | |
| PATRIOTIC | 9361469 | |
| RAMA-1 | 8306711 | |
| RAWAN | 8697304 | |
| SCHUMI | 9134359 | Formerly IRIS GAS |
| SEA SHARK | 8919154 | |
| SENNA 8 | 9128673 | Formerly ODYN GAS |
| SIENNA | 9147447 | |
| SINCERO | 9254422 | |
| STALINGRAD | 9690212 | |
| TIMBUKTU | 9015345 | Formerly BUKHARA |
| TRUE OCEAN | 9169421 | |
| TRUVOR | 9676230 | Formerly MUKHALATKA |
| UNICOM ALPHA | 9133393 | |
| VALE | 9391153 | |
| VITO | 9079195 | |
| VOLGA | 9104770 | Formerly MARSHAL ZHUKOV |
3: Recent Legislative and Policy Developments (June 2025)
Bipartisan Caesar Act Repeal Bill (June 19, 2025):
- Summary: A bill was introduced in the U.S. Senate by Senators Shaheen and Paul to fully repeal the Caesar Act.
- Implication: This is the most significant development toward de-risking Syria for international investors. If passed, it would eliminate the threat of U.S. secondary sanctions, opening the door for non-U.S. banks and companies to engage in large-scale reconstruction without fear of being cut off from the U.S. financial system. This action provides strong evidence of a durable, bipartisan U.S. policy shift.
SWIFT System Re-integration (Reported June 19, 2025):
- Summary: News reports indicate Syria completed its first direct commercial transaction via SWIFT with an Italian bank.
- Implication: This is a landmark operational development, proving that a financial channel to Europe is viable. It serves as a powerful precedent that can be used to persuade other risk-averse banks to process compliant transactions.
Key Resources
- OFAC: Sanctions List Search Tool, Syria Sanctions Page
- Department of Commerce (BIS): Export Administration Regulations
- Congress: www.congress.gov (for tracking legislation)
- News & Analysis: Atlantic Council, Washington Institute for Near East Policy, International Crisis Group.
- Legal & Compliance Expertise: Engage with law firms specializing in U.S. sanctions (e.g., Baker McKenzie, Covington, Arnold & Porter mentioned in source documents).
IMPORTANT DISCLAIMER: For Informational Purposes Only
The information contained in this report is provided for general informational and educational purposes only and is not intended to be, and should not be construed as, legal, financial, investment, compliance, or professional advice. This document does not constitute a substitute for obtaining advice from a qualified professional, including legal counsel specializing in U.S. sanctions and export control laws.
No Attorney-Client Relationship: The provision and receipt of this information do not create an attorney-client relationship or any other professional relationship between the author/provider and the user.
Currency and Accuracy of Information: This analysis is based on source materials and information available as of June 22, 2025. The legal and regulatory landscape of U.S. sanctions is highly dynamic and subject to frequent and significant change, often with immediate effect and without prior notice. The U.S. Government may amend regulations, issue new Executive Orders, pass new legislation, or update its sanctions lists (including the SDN List) at any time. We make no representation or warranty, express or implied, regarding the accuracy, completeness, or timeliness of the information contained herein.
Not Exhaustive: This report is not an exhaustive summary of all applicable U.S. or international laws and regulations concerning Syria. It may not identify all designated parties, relevant statutes, or potential risks associated with engaging in transactions related to Syria. The analysis is limited to the specific source documents referenced and does not purport to cover all aspects of this complex subject matter.
No Warranty or Liability: This document is provided "as is." Reliance on any information provided in this report is solely at the user's own risk. The author/provider disclaims all liability for any actions taken or not taken based on the contents of this report, or for any loss or damage of any kind arising from its use.
User Responsibility and Requirement for Independent Verification: All persons and entities are solely responsible for ensuring their own compliance with all applicable laws and regulations. Before making any business, investment, or legal decision, users must consult with qualified, independent legal counsel and other relevant professionals. All information, particularly regarding sanctioned entities and specific prohibitions, must be independently verified against official, primary-source government publications.
Official Sources for Verification Include:
- U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC): For the latest sanctions lists, regulations, and guidance. (https://ofac.treasury.gov)
- U.S. Department of Commerce, Bureau of Industry and Security (BIS): For the Export Administration Regulations (EAR) and the Commerce Control List (CCL). (https://www.bis.doc.gov)
- U.S. Department of State, Directorate of Defense Trade Controls (DDTC): For the International Traffic in Arms Regulations (ITAR) and the U.S. Munitions List (USML). (https://www.pmddtc.state.gov)
- U.S. Congress: For the full text of enacted legislation. (https://www.congress.gov)
- The Federal Register: For all official notices, rules, and orders. (https://www.federalregister.gov)