Recent developments have significantly altered the sanctions landscape for Syria.  The United States, the European Union and the United Kingdom have implemented substantial relaxations, particularly in relation to state-linked entities and sectors central to trade and reconstruction. However, critical restrictions remain in place and compliance risk must still be assessed on a case-by-case basis.

United States – OFAC General License (May 2025)

On 22 May 2025, the U.S. Department of the Treasury (OFAC) issued a General License lifting the bulk of U.S. sanctions targeting Syria until further notice. This includes the suspension of prohibitions under Executive Orders 13572 and 13582, the Syrian Sanctions Regulations (31 CFR Part 542), and the Caesar Syria Civilian Protection Act.

The General License 25 now permits transactions involving the Government of Syria and Syrian state-owned entities, provided they are listed in the annex to the license. Permissible activities include:

• Dealings with the Central Bank of Syria and state institutions under the transitional government;
• Maritime trade with Syria, including chartering, port calls, and payments for port services at locations such as Latakia and Tartous;
• Import and export of non-military goods including petroleum products, construction materials, and humanitarian items;
• Banking, financing, and payment services in connection with the above.

Key limitations remain, however, namely transactions involving designated persons (SDNs) are prohibited unless those entities are explicitly listed in the annex to the GL or fall under the 50% ownership rule. Port authorities and petroleum entities of commercial relevance are included in the annex.

Property blocked prior to 22 May 2025 remains frozen, even if the SDNs are listed in the annex. This may affect legacy claims involving banks that froze funds under prior Syria-related designations.

U.S. export controls under ITAR and EAR continue to apply. Transactions that overlap with other U.S. sanctions regimes (e.g. Iran, Russia) may remain restricted regardless of this General License.

Separately, the U.S. Department of State has issued a 180-day waiver of sanctions under Section 7412 of the Caesar Act. Amongst other things, this waiver suspends secondary sanctions exposure for foreign (non-U.S.) persons engaging in activity now authorised by the General License.

From a U.S. law perspective, the framework for lawful trade with Syria has reopened significantly. However, due diligence remains essential, particularly to identify residual SDN exposure or overlapping export control risks. OFAC has issued a useful fact sheet that may be found here.

European Union – Sanctions on maritime and petroleum entities delisted

On 28 May 2025, the EU implemented Regulation EU 2025/1094 amending Regulation EU No.36/2012 concerning restrictive measures in view of the situation in Syria.  asset freeze restrictions on the following core maritime and oil industry actors were removed:

• Syria Trading Oil Company (Sytrol)
• General Petroleum Corporation (GPC)
• Al Furat Petroleum Company
• Ebla Petroleum Company
• Dijla Petroleum Company
• Syrian Petroleum Company
• Mahrukat Company
• Syrian Company for Oil Transport
• The Baniyas Refinery Company
• The Homs Refinery Company
• Overseas Petroleum Trading

These companies encompass upstream production, transport, refining, and export infrastructure relevant to charterers, bunker suppliers, and operators calling at Syrian ports.

This development comes in addition to the previous lifting of most trade-based EU sanctions against Syria – including those involving the petroleum sector. However, some trade-based sanctions remain in place – particularly with regards to military goods.

United Kingdom – Amendments to Syria (Sanctions) Regulations

On 24 April 2025, the UK Government enacted the Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025, which came into force on 25 April 2025.  These amendments lifted asset freeze restrictions on 24 Syrian entities, including the Central Bank of Syria, Syrian Arab Airlines, and several major energy and logistics companies. Additionally, sanctions were removed from the Ministries of Defence and Interior, as well as multiple Syrian intelligence agencies.

The UK’s stated objective is to support Syria’s political transition and post-conflict reconstruction. However, some trade-based sanctions remain in force, particularly those linked to military goods, surveillance equipment, and dual-use items. As with the U.S., each proposed transaction must be reviewed in its full factual context to ensure compliance.

Sanctions Due Diligence Questionnaires (S-DDQs) remain mandatory for all voyages to/from Syria where TSC is the quoting War AP lead or issuing SOL cover.

Internal case-by-case review continues to apply for any Syria-linked risk, given the evolving regulatory framework and potential reimposition risks.