U.S. Eases Syrian Sanctions

On December 23, 2025, the U.S. Department of State, the Department of Commerce, and the Office of Foreign Assets Control (OFAC) within the Department of the Treasury published amended guidance on U.S. sanctions programs involving Syria. This “Amended Tri-Seal Advisory” explains recent changes which have lifted almost all of those programs. It was updated to include the repeal of the Caesar Syria Civilian Protection Act of 2019 (Caesar Act), enacted by President Trump on December 18, 2025. President Trump already lifted most sanctions on Syria in June 2025 due to the removal of Bashar al-Assad and creation of a new government under President Ahmed al-Sharaa.

What was the Caesar Act?

The Caesar Syria Civilian Protection Act of 2019 was passed by Congress to require mandatory sanctions against any foreign persons that (1) provided “significant support” or engaged in a “significant transaction” with the Syrian government or acted on its behalf; (2) committed serious human rights abuses against the Syrian people; or (3) provided certain goods or services to the Syrian government such as aircraft or munitions. The act was originally passed to respond to war crimes and human rights abuses committed by the Assad government during the Syrian Civil War. Its repeal was included in the annual National Defense Authorization Act for 2026, which sets the budget for the U.S. Department of the Defense.

This reflects a significant change in U.S. foreign policy. With Syria under the new leadership of President Ahmed al-Sharaa, the former Emir of the ​​Al-Nusra Front, the U.S. now seeks to promote rather than restrict the country’s development. This change in direction was already embraced earlier in May 2025 by President Trump, who seeks to give Syria “a chance at greatness” according to the Tri-Seal Advisory. Trump cited “positive actions taken by the new Syrian government” as part of the changed circumstances underlying his revocation of the comprehensive sanctions targeting Syria on June 30, 2025.

What’s changing about sanctions on Syria?

Most of the changes outlined in the guidance document are already several months old by now. The amendment on December 23 only added the repeal of the Caesar Act. Now, with the removal of the mandatory sanctions required by the Act, almost all of the U.S. sanctions targeting Syria and its government have been eliminated. The only remaining prohibitions are restrictions on the transfer of dual-use goods, civilian goods which could be put to military use, which requires an export license. There are no longer any sanctions restricting the transfer of most basic civilian use goods, software, and technology to Syria.

Sanctions designations on Bashar Al-Assad, his associates, and alleged human rights abusers and captagon traffickers. Captagon trafficking was once a significant source of funding for the Assad government during the Syrian Civil War, during which 80% of the world’s captagon supply was produced in the country.

About Sanctions Law Center

The elimination of most sanctions targeting Syria does not mean the elimination of all sanctions-related risks in dealings involving the country. Some sanctions remain on certain individuals and entities within the country, and compliance issues may also arise due to mistakes made during the transition to a relatively sanctions-free environment. It is therefore wise to consult a sanctions lawyer before engaging in a transaction or business operation in Syria. At Sanctions Law Center, our OFAC Attorneys will provide you with expert compliance counseling to advise you on the possible implications of sanctions regimes on their operations.

The best way to avoid sanctions-related risks is through a well-designed compliance program. Strong sanctions screenings proceedings will prevent a lot of potential compliance issues that might arise from doing business in Syria. The OFAC Lawyers at Sanctions Law Center have years of experience helping our clients craft sanctions compliance programs tailored to their needs. Whether you need help mitigating sanctions-related risks, dealing with compliance issues, or preventing them from arising in the first place, our OFAC Lawyers can help.