Impact of Syria Sanctions on Businesses and Their Anti-Money Laundering Regulations
Syria's economic landscape is undergoing significant changes, following the relaxation of sanctions by both the United States and the European Union. As of mid-2025, most countries are now allowed to trade with Syria, albeit with careful compliance regarding remaining targeted sanctions and export controls.
United States
On June 30, 2025, President Trump issued Executive Order 14312, effectively ending the national emergency with respect to Syria and revoking prior broad sanctions. The U.S. Treasury’s OFAC removed the comprehensive Syria Sanctions Regulations and replaced them with a more targeted Promoting Accountability for Assad and Regional Stabilization Sanctions program.
The previous broad embargo is lifted, and all items subject to U.S. Export Administration Regulations (EAR) that were anti-terrorism classified or EAR99 (low risk) are now authorized for export to Syria, with expanded license exceptions and a higher de minimis threshold (from 10% to 25% non-U.S. content). However, a license is still required for most exports or re-exports of U.S. items to Syria, except food and medicine, and there remains a general policy of denial until new rules are finalized, expected within 1-2 months post-July 2025.
Certain sanctions remain in place against Bashar al-Assad, his associates, human rights abusers, terrorist groups including ISIS, and alleged Iranian proxies. The Caesar Syria Civilian Protection Act sanctions are still under review, with conditions to be met including cessation of targeting civilians, release of political prisoners, allowance of displaced persons' return, and accountability for war crimes before suspension.
European Union
The EU has also lifted nearly all sanctions on Syria, aligning with the U.S. move to support Syria’s reintegration into international trade and finance. EU restrictions that previously limited Syria’s access to financial and commercial systems have been removed, though compliance with international human rights standards in reconstruction efforts is urged by UN experts.
Conditions and Trade Allowed
Trade is now generally allowed with Syria by countries subject to U.S. and EU jurisdiction, subject to compliance with any remaining targeted sanctions (e.g., those on specific individuals or entities). Exports of food, medicine, and many dual-use items are authorized under expanded license exceptions, but some sensitive technology or military-related goods may still require licenses.
Countries trading with Syria must conduct rigorous due diligence, including “know your customer” (KYC) and screening to avoid dealings with designated persons or entities. Reconstruction and commercial assistance should respect human rights principles and avoid reinforcing sectarian or ethnic divisions.
Key Points
- Trade with Syria is now generally allowed, subject to compliance with remaining targeted sanctions.
- Exports of food, medicine, and many dual-use items are authorized under expanded license exceptions.
- Due diligence, including “know your customer” (KYC) and screening, is required to avoid dealings with designated persons or entities.
- Reconstruction and commercial assistance should respect human rights principles and avoid reinforcing sectarian or ethnic divisions.
While the situation is evolving with further regulatory guidance expected soon, it's crucial for companies to stay informed and comply with the regulations to avoid potential fines and reputational damage. The landscape of trade with Syria is changing, offering opportunities for economic growth and development, but also carrying risks that must be carefully managed.
- This new development in Syria's economy, with the lifting of sanctions by both the United States and the European Union, opens up finance avenues that were previously restricted, presenting opportunities for lifestyle improvement and technological advancement within the Syrian economy.
- As the general-news unfolds, the sports sphere might soon see Syria participate in international events, considering the positive economic impact of the relaxation of sanctions, which could pave the way for increased corporate involvement, thereby boosting the overall financial status of the country.