Is Syria a Sanctioned Country? Caesar Act, Licenses, 50% Rule

Syria is no longer a comprehensively sanctioned country under U.S. law. On June 30, 2025, President Trump signed Executive Order 14312, revoking the six executive orders that had built the Syria sanctions program since 2004. The change took effect July 1, 2025. U.S. persons can now trade with, invest in, and send payments to Syria without the blanket prohibitions that governed for over two decades. Targeted sanctions still apply to Bashar al-Assad, his associates, human rights abusers, Captagon traffickers, and anyone tied to terrorism or weapons proliferation.

What Changed on July 1, 2025

For most of the last twenty years, dealings with Syria operated under a default of “prohibited unless authorized.” Executive Order 13582 had blocked all property of the Syrian government and barred U.S. persons from investing in Syria, exporting services, or dealing in Syrian petroleum. Five other executive orders layered on further restrictions. The Syrian Sanctions Regulations at 31 CFR Part 542 pulled it all together into a wall of prohibitions.

After the fall of Assad’s government in December 2024 and the establishment of a new government under President Ahmed al-Sharaa, U.S. policy shifted quickly. Executive Order 14312 terminated the underlying national emergency and revoked all six foundational executive orders.¹ OFAC is removing the Syrian Sanctions Regulations from the Code of Federal Regulations entirely.²

The default has flipped. U.S. persons can invest in Syria, export goods and services, and engage in ordinary commercial transactions. Financial institutions can process payments involving Syrian counterparts, open correspondent accounts with Syrian banks, and finance trade, as long as none of the parties are on the SDN list.³ All Syrian financial institutions, including the Central Bank of Syria, were removed from the SDN list. The petroleum trade prohibitions are gone. Export restrictions under the Syria Accountability Act were waived on national security grounds.¹

Who and What Is Still Sanctioned

The lifting of comprehensive sanctions does not mean everyone connected to Syria is clear to transact with. Executive Order 13894, as amended by the June 30 order, remains the legal basis for targeting specific categories of people. Concurrently with the revocation, OFAC redesignated 139 individuals and entities under E.O. 13894 or other authorities so they would remain restricted under the new framework.³

Sanctions still apply to:

Bashar al-Assad and his associates. Assad’s own SDN listing under program tag PAARSSR-EO13894 keeps his assets frozen and bars any U.S. person from transacting with him.⁴
Individuals responsible for war crimes or serious human rights violations in Syria.
Captagon traffickers involved in the drug trade that funded the former regime.
Persons connected to Syria’s past chemical weapons or other proliferation activities.
ISIS, Al-Qa’ida affiliates, and Iran-linked proxies operating in Syria.

Anyone who had been designated solely under one of the six revoked executive orders was removed from the SDN list and their assets unblocked. Anyone also designated under a different authority (E.O. 13894, counterterrorism programs, nonproliferation programs) stays on the list.³

The Caesar Act Is Not the Barrier It Was

The Caesar Syrian Civilian Protection Act of 2019 mandated sanctions on anyone providing significant support to the Syrian government. Because it is a statute rather than an executive order, the president could not revoke it. On May 23, 2025, Secretary of State Marco Rubio waived the imposition of Caesar Act sanctions for 180 days, and the June 30 executive order directed the Secretary to consider extending or broadening that suspension.² Congress then moved to eliminate the statute entirely, with a repeal provision included in the Fiscal Year 2026 National Defense Authorization Act.⁵

The practical effect is that the Caesar Act no longer blocks doing business with Syria. Conduct that would have triggered Caesar Act sanctions during the period they were active could still draw scrutiny.

Due Diligence and the 50% Rule

Comprehensive sanctions being lifted makes screening more important in some ways, not less. When a whole country was off-limits, many companies simply stayed out. Now the job is to distinguish permitted counterparties from blocked ones. OFAC “strongly encourages financial institutions to employ a risk-based sanctions compliance approach” when engaging with Syria.³

Screen every counterparty against the Consolidated Screening List, which aggregates the SDN list, the Entity List, the Denied Persons List, and other restricted-party lists covering export controls and nonproliferation.⁶

OFAC’s 50 percent rule still applies to everyone who remains on the SDN list. If one or more blocked persons own 50 percent or more of an entity in the aggregate, that entity is also blocked, even if it is not itself named. Ownership interests of persons blocked under different sanctions programs are combined for this calculation.⁷ A company 30 percent owned by one remaining SDN and 25 percent owned by another is treated as blocked, though neither holds a majority stake.

A sound compliance program includes senior management commitment, regular risk assessments, clear internal controls for identifying and escalating flagged transactions, routine testing and auditing, and ongoing staff training. These are the components OFAC looks for when evaluating whether a company took sanctions seriously.

Past Violations Are Still Enforceable

Revocation is not amnesty. OFAC has stated that pending or future investigations and enforcement actions for apparent violations that occurred before July 1, 2025 may still be carried out.³ If you exported services to Syria in 2022 without authorization, that violation is still enforceable.

The penalty framework under the International Emergency Economic Powers Act remains in place. The baseline civil penalty runs up to $250,000 per violation or twice the value of the underlying transaction, whichever is greater, adjusted annually for inflation. Willful violations can bring criminal penalties of up to $1,000,000 in fines and 20 years in prison for individuals.⁸

The enforcement risk is real. In February 2026, OFAC announced a $3,777,000 settlement with a U.S. person who had served as an officer and board member for four Syrian real estate companies, providing managerial services to luxury real estate projects in Syria between January 2018 and December 2021. The settlement was for “apparent violations of OFAC sanctions on Syria previously in effect.”⁹ The conduct predated the revocation by years; the enforcement action came months after sanctions were lifted.

Going forward, violations involving remaining SDN-listed persons or other active authorities (counterterrorism, nonproliferation, Iran-related) carry the same IEEPA penalties, and asset forfeiture remains available to federal agencies.

Blocked Property Reporting

If you still hold property that remains blocked because it belongs to someone who stayed on the SDN list after July 2025, reporting obligations continue. Initial reports on newly blocked property must be filed with OFAC within 10 business days of the date the property becomes blocked, and the same 10-day window applies when blocked property is unblocked or transferred.¹⁰ Holders must also file an Annual Report of Blocked Property covering all blocked assets held as of June 30 each year. The deadline for the 2026 report is September 30, 2026. Missing it is itself a regulatory violation.¹¹

When You Still Need a License

If a proposed transaction touches an active prohibition (typically because a party is a remaining SDN), you can apply for a specific license from OFAC when no general license covers the activity. Applications go through OFAC’s online portal.¹² Explain the transaction, identify the parties, and set out why authorization is warranted. Approval is not guaranteed and processing times vary, so build lead time into any deal.

General License 25, issued May 23, 2025, still authorizes certain transactions involving blocked persons listed in its annex. It excludes transactions involving SDNs not listed in that annex, transactions involving the governments of Russia, Iran, or North Korea, and the unblocking of property that was blocked as of May 22, 2025.¹³ If your transaction falls outside both GL 25 and the broad revocation, a specific license is the remaining path.

1
The White House. Providing for the Revocation of Syria Sanctions
2
Office of Foreign Assets Control. Syria Sanctions – Inactive and Archived
3
Office of Foreign Assets Control. FAQs 1220-1223
4
U.S. Department of the Treasury. Sanctions List Search – Details
5
U.S. Senate Committee on Foreign Relations. ICYMI: Shaheen Secures Repeal of Caesar Act Sanctions on Syria in Annual Defense Bill
6
International Trade Administration. Consolidated Screening List
7
Office of Foreign Assets Control. Entities Owned by Blocked Persons (50% Rule)
8
Office of the Law Revision Counsel. 50 USC Ch. 35 – International Emergency Economic Powers – Section 1705 Penalties
9
Office of Foreign Assets Control. An Individual Settles with OFAC for $3,777,000 Related to Apparent Violations
10
eCFR. 31 CFR 501.603 – Reports of Blocked, Unblocked, or Transferred Blocked Property
11
Office of Foreign Assets Control. Reminder to File the 2025 Annual Report of Blocked Property
12
Office of Foreign Assets Control. OFAC Specific Licenses and Interpretive Guidance
13
Federal Register. Publication of Syrian Sanctions Regulations Web General License 25