On June 30, 2025, the U.S. Department of the Treasury announced a major shift in foreign policy: the revocation of the broad U.S. sanctions program targeting Syria. This move, formalized through Executive Order, marks the end of over a decade of country-based sanctions and introduces a new, narrower framework: the Promoting Accountability and Regional Reconciliation in Syria Sanctions ("PAARSS") program.
While the change opens new avenues for engagement, it also introduces a new compliance landscape that requires immediate attention from legal and risk professionals.
What Changed?
- Effective July 1, 2025, the Syria Sanctions Regulations (31 CFR Part 542) were officially removed from the Code of Federal Regulations.
- OFAC has archived prior Syria-related FAQs, General Licenses, and guidance.
- A new targeted program, PAARSS, now governs U.S. sanctions related to Syria.
- OFAC released FAQs 1220–1223 to help the public understand what's allowed and what remains prohibited.
- Some individuals and entities previously sanctioned under Syria authorities were delisted, while others may remain sanctioned under different legal authorities (e.g., counterterrorism, Magnitsky). Additionally, State Department restrictions (e.g., State Sponsor of Terrorism") remain. (This is likely to change: Executive order 14312 directed the Secretary of State to "take all appropriate action" to review current restrictions.)
What Does This Mean for Businesses and Compliance Teams?
While this development removes many restrictions, it does not mean Syria is a risk-free jurisdiction.
Here are some of the key takeaways:
- Screening and watchlists must be updated to reflect delistings and reclassifications under PAARSS.
- Legacy Syria General Licenses and authorizations are no longer valid and should not be relied upon.
- Due diligence remains critical, especially where counterparties may be linked to human rights abuses, corruption, or interests of the former al-Assad regime.
- Unless sanctioned under another authority (e.g., PAARSS or global Magnitsky), many transactions involving Syria are now generally permitted.
- Before green lighting a transaction, consider State Department restrictions.
- Ongoing monitoring is essential; PAARSS is likely to evolve, and new designations could emerge at any time.
Why It Matters
For companies operating globally, this is more than a regulatory update. It also reflects a strategic shift in U.S. sanctions policy. The move away from blanket embargoes toward more targeted designations signals a trend toward "smart sanctions" that focus on individual accountability over broad geographic restrictions.
This regulatory shift underscores the importance of maintaining flexible and adaptive compliance programs that can quickly align with emerging legal frameworks, something especially vital for companies navigating multiple jurisdictions with overlapping or conflicting regulations.
Key Action Items
- Update screening protocols and compliance databases (or ensure that your tool provider has done so).
- Review OFAC's new FAQs and guidance.
- Communicate the changes internally, especially to those involved in high-risk transactions.
- Monitor PAARSS developments and future designations.
- Consult legal counsel before resuming any transactions involving Syrian entities or assets.
Final Thought
We cannot emphasize this enough: Sanctions relief does NOT mean risk elimination. The revocation of the Syria sanctions opens the door to new opportunities, but only for those with appropriate compliance controls in place.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.