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On June 30, 2025, President Trump issued Executive Order 14312 (“E.O. 14312” or the “E.O.”) titled “Providing for the Revocation of Syria Sanctions,” which terminates, effective July 1, 2025,  the longstanding U.S. sanctions program against Syria.  Sanctions remain in effect on deposed President Bashar al-Assad and other wrongdoers associated with him or his administration.  

In a press release, the U.S. Department of the Treasury explained that “[t]he circumstances that gave rise to OFAC's Syria sanctions program, related to the brutal former regime of Bashar al-Assad, have been transformed by developments over the past six months, including the positive actions taken by the new Syrian government under President Ahmed al-Sharaa.”  U.S. Treasury Secretary Scott Bessent said the action “will help provide the opportunity to reconnect Syria's economy with global commerce and rebuild the country's infrastructure.”  

Syria was designated a State Sponsor of Terrorism in 1979.  In 2003, Congress enacted the Syria Accountability and Lebanese Sovereignty Restoration Act, which led President George W. Bush, through the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”), to impose sanctions on Syria in 2004.  In the ensuing years, the sanctions were intensified several times, resulting in a near-total U.S. embargo.    

E.O. 14312 lifts the embargo, and removes sanctions against individuals and entities previously included on OFAC's Specially Designated Nationals and Blocked Persons List (the “SDN List”).  The E.O. also removes the designation of Syria as a State Sponsor of Terrorism.  

In addition, E.O. 14312 waives restrictions imposed on Syria in 2013 based on Syria's use of chemical weapons, including restrictions related to foreign assistance, U.S. government credit and other financial assistance, exports of U.S. technology and other goods, and loans and credit from U.S. financial institutions.

OFAC's FAQ 1221 explains that “[a]ll Syrian financial institutions, including the Central Bank of Syria, have been removed from” the SDN List.  U.S. persons are no longer prohibited from providing financial services to Syria, processing payments on behalf of third country financial institutions involving Syrian financial institutions, or conducting transactions with the new Government of Syria and Syrian financial institutions (provided that none of the involved parties are on the SDN List for other reasons). 

Sanctions remain in place  against Assad and his confederates under a new OFAC program titled “Promoting Accountability for Assad and Regional Stabilization Sanctions (PAARSS).”  Sanctions also remain in effect against human rights abusers, traffickers in Captagon (an illicit drug used to generate revenue for the Assad regime), persons linked to Syria's past proliferation activities, affiliates of ISIS and Al-Quaeda, and Iran and its proxies.  

For the first time in many years, U.S. persons, including banks, may engage in commercial activity with Syria. Still, sanctions remain in effect on bad actors linked to the former government of Syria, and guidance by counsel is warranted.  Katten stands ready to assist.