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Sanctions - Syria

Overview

Following the fall of the Assad regime in December 2024, the United States, United Kingdom and European Union have each undertaken substantial and staged rollbacks of the extensive sanctions frameworks that had been in place against Syria since 2011–2012.

The primary objective of these relief measures is to promote Syria's reconstruction and economic recovery, facilitate humanitarian assistance, and support the new transitional government.

Although the three sanctions regimes differ in their detail, in broad terms the following activities of potential interest to the maritime industry are now permitted:

  • Undertaking transactions with Syrian banks
  • Carriage of jet fuel and additives to Syria
  • Carriage of crude oil and petroleum products to and from Syria
  • Carriage of equipment related to crude oil/natural gas production and to electricity production in Syria
  • Delivery of humanitarian aid

However, these rollbacks are not total. A significant number of designated individuals and entities remain subject to asset freezes, and certain trade and activity prohibitions continue to apply across all three jurisdictions.

Also, not all three sanctions regimes are fully aligned. The scope of relief, the persons and entities that remain designated, and the specific prohibitions that continue to apply differ between the US, UK and EU regimes.

Member Advisory

Members are strongly advised to continue to conduct careful, jurisdiction-specific due diligence before undertaking any Syria-related activity.

United States

Remaining US Sanctions and Prohibitions

Despite the broad rollback, the following restrictions and designations continue to apply:

  • Persons designated under authority other than the revoked E.O.s remain on OFAC’s SDN List, including Bashar al-Assad and other former regime enablers, as well as individuals designated under counter-terrorism (E.O. 13224) and other programmes.
  • 139 individuals were redesignated by OFAC on 30 June 2025 under E.O. 13894 (as further amended by E.O. 14312) targeting war crimes perpetrators, human rights abusers, narcotics traffickers, and proliferators linked to the former Assad regime.
  • The national emergency under E.O. 13894 (as further amended) remains in effect, maintaining sanctions authority over persons contributing to instability in Syria, human rights violators, and chemical weapons-related actors.
  • GL 25 does not authorise transactions involving or for the benefit of the Governments of Russia, Iran, or North Korea.

Relevant Resources

OFAC – Syria Sanctions (Inactive/Archived) – Historical programme page including SySR removal and GL 25
OFAC / State / Commerce – Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria (updated December 2025)
Executive Order 14312 (30 June 2025) – Providing for the Revocation of Syria Sanctions (Federal Register)
BIS – Export Controls for Syria (including License Exception SPP) – Bureau of Industry and Security
OFAC SDN List – Searchable list of all remaining designated persons and entities
OFAC General License 25 – Authorizing transactions involving certain blocked persons

European Union

The EU - Syria sanctions framework is anchored in Council Regulation (EU) No 36/2012 of 18 January 2012 concerning restrictive measures in view of the situation in Syria, as amended, and Council Decision 2013/255/CFSP of 31 May 2013, as amended. Enforcement is the responsibility of individual EU Member States, with guidance provided by the European Commission. Member States’ National Competent Authorities (NCAs), identified in Annex III of Regulation 36/2012, are the first point of contact for compliance questions.

Remaining EU Sanctions and Prohibitions

Despite the broad lifting of economic sanctions, the following measures remain in force under Regulation (EU) No 36/2012 (as amended) and related instruments:

  • Import of arms and related materiel from Syria (financing and financial assistance of Common Military List imports also prohibited).
    • Note: EU Syria sanctions do not constitute a full arms export embargo, but Member States may apply national controls. Article 2d of Regulation 36/2012 enables Member States to apply the dual-use catch-all clause for items intended for military end-use in Syria.
  • Export, supply, or transfer to Syria of goods, technology, equipment, or software intended for:
    • internal repression or torture;
    • monitoring or interception of internet or telecommunications;
    • manufacture or maintenance of items for internal repression.
  • Asset freeze and travel ban measures continue to apply to over 350 individuals and approximately 67 entities listed in the Annexes to Regulation 36/2012. These include persons linked to the former Assad regime, chemical weapons actors, and human rights abusers.
  • The Syrian Ministry of Defence and Ministry of Interior remain subject to asset freeze measures (subject to licensing for specific cooperation activities).
  • Export of dual-use goods with military end-use in Syria requires heightened scrutiny; Member States retain discretion to prohibit such exports under Article 2d.

NOTE (Snapback): The May 2025 EU lifting measures were designed as staged and reversible. The Council retains the power to reimpose suspended measures should the situation in Syria deteriorate. Parties should monitor developments and Council statements for any indication of snapback risk.

Relevant Resources

Council Regulation (EU) No 36/2012 – Consolidated text (as of 24 September 2025) – Primary legislative instrument
Council Decision 2013/255/CFSP – Consolidated text (as of 24 September 2025)
European Commission – FAQs on EU Syria Sanctions (November 2025)
EU Sanctions Map – Interactive tool for current EU designations and measures
EU Council – Syria Sanctions Timeline and Press Releases
EU Consolidated Financial Sanctions List – Searchable database of all EU designated persons

United Kingdom

UK Syria sanctions are imposed under the Sanctions and Anti-Money Laundering Act 2018 and implemented through the Syria (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/792) (the “2019 Regulations”), as amended.

Separately, certain Syrian individuals are subject to the ISIL (Da’esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019, implementing UN Security Council Resolution 1267 (1999) counter-terrorism measures.

Remaining UK Sanctions and Prohibitions

The following prohibitions and designations remain in force under the 2019 Regulations (as amended):

  • Export to Syria of goods, technology or equipment that might be used for
    • internal repression or torture;
    • monitoring or interception of internet or telecommunications;
    • chemical or biological weapons manufacture or delivery.
  • Import of arms and related materiel from Syria.
  • Export of luxury goods to Syria (Regulation 46 of the 2019 Regulations).
  • Trade in gold, precious metals, and diamonds with Syrian authorities (Regulation 45).
  • The ISIL (Da’esh) and Al-Qaida sanctions regime continues to apply to entities listed under that regime (including HTS).

Relevant Resources

Syria (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/792) – as amended, primary legislative instrument
FCDO/OFSI – Syria Sanctions Guidance (updated July 2025)
FCDO – Supporting Syria’s Future: Guidance for Businesses and NGOs (December 2025)
UK Sanctions List – Searchable list (sole official source since 28 January 2026; replaces OFSI Consolidated List)
OFSI General Licence INT/2025/5810196 – Humanitarian assistance / basic human needs in Syria
GOV.UK – UK Sanctions Hub (central portal for all UK sanctions content)

Important note

The information provided by the Club and in particular through its website is not and is not intended to be exhaustive. Every effort is made to ensure the accuracy of the information provided. However this cannot be guaranteed given that sanctions measures are subject to alteration by Governmental organisations at short notice. Further the information on this site is not, and should not be relied upon as, independent legal advice.

Members are strongly advised to undertake due diligence before fixing any business to or from a sanctioned country in order to ensure that neither the prospective cargo nor the parties to the planned venture are sanctioned. The Club is willing to assist Members where possible but they may nevertheless wish to take independent legal advice.