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Companies engaged in international trade, particularly those involving Syrian nationals or goods, should take note of recent legal developments. Following the publication of Executive Order ("E.O.") 14312 on June 30, 2025, the Bureau of Industry and Security ("BIS") and the Office of Foreign Assets Control ("OFAC") have released final rules that significantly alter the landscape of US sanctions and export controls on Syria.
These final rules, issued between August 26, 2025 and September 2, 2025, (1) terminate the Syrian Sanctions Regulations originally implemented in 2005 and reissued in 2014 and (2) significantly relax restrictions on many exports to Syria.
OFAC Final Rule
The "Syrian Sanctions Regulations" were originally enacted via E.O. 13338 in 2005, based on the Syrian government's support for terrorism, occupation of Lebanon, pursuit of weapons of mass destruction, and interference in U.S. and international stabilization efforts in Iraq.
On August 26, 2025, OFAC issued a final rule \consistent with E.O. 14312, formally revoking the Syrian Sanctions Regulations (31 CFR part 542). OFAC determined that the circumstances underlying the original national emergency declaration and sanctions had fundamentally changed over the six months leading up to June 30, 2025.
With the issuance of E.O. 14312 and the new final rule, OFAC removed these regulations from the Code of Federal Regulations. However, prior sanctions still apply to any actions taken or proceedings initiated before July 1, 2025, and to any rights or penalties that matured or were incurred before that date.
Looking ahead, OFAC plans to consolidate the applicable Syria-related provisions into a new, narrower framework: the Promoting Accountability and Regional Reconciliation in Syria Sanctions ("PAARSS"). This framework will be implemented through a separate rulemaking process. Companies should monitor for updates (or simply subscribe to our newsletter!)
CAUTION: Syria remains designated a State Sponsor of Terrorism. Additionally, a number of restricted entities, persons, and uses are still blocked. As a consequence, counterparty and transactional screening remain crucial.
BIS Final Rule
On August 2, 2013, the US government concluded that the Government of Syria used chemical weapons against its own nationals in violation of international law. Syria, already subject to sanctions, became subject to heightened restrictions on EAR-controlled items for national security reasons.
That regime no longer controls Syria. On September 2, 2025, BIS published its final rule aligning with E.O. 14312. The rule amends the Export Administration Regulations ("EAR") by making three significant changes to export control measures for Syria:
- Expanded License Exceptions: New or broadened eligibility for license exceptions covering exports and reexports to Syria.
- More Permissive License Review Policies: A more favorable review policy for export and reexport applications with a presumption of approval (consistent with US national security and foreign policy interests, as well as the objectives of E.O. 14312 to support peace, stability, and prosperity in Syria).
- Conforming and Streamlining Updates: Removal of outdated provisions, including references to the now-terminated Syrian Sanctions Regulations.
As of September 2, 2025, EAR99 items (excepting food and medicine) require authorization but are permitted under license exception (Syria Peace and Prosperity) at CFR §740.5.
CAUTION: Licenses (and license exceptions) must be monitored as they can be withdrawn at any time. Additionally, while licenses are more favorably reviewed, the Firm has encountered significant delays in processing time. Also, EAR99 items are not free of regulations: licensed transactions remain subject to end use and end user restrictions under Part 744 of the EAR. Finally, goods on the Commerce Control List continue to be restricted.
Final Note: Compliance Still Matters
The situation in Syria remains politically and militarily unstable. It is unclear whether the current US view towards the current regime will shift in the future.
Also, and as noted in our previous post on E.O. 14312: Sanctions relief does NOT mean risk elimination. The revocation of certain sanctions and the loosening of export controls may open the door to both new opportunities and new risks; the latter can be mitigated through constant monitoring and robust compliance procedures.
Finally, the US is not the only sanctions regime in town: other potentially applicable restrictions remain (e.g., due to UK and EU sanctions and arms embargos). For all transactions, consider all applicable sanctions regimes and act accordingly.
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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.
