American Club has informed its members that, while broad US sanctions on Syria had now been lifted, Club cover remained unavailable for any trade that violated applicable sanctions or involved blocked individuals or entities under the updated framework (e.g. those listed under EO 13894). Therefore due diligence by Members remained essential.
“Importantly, OFAC may still pursue enforcement actions for any apparent violations of the Syria sanctions programme (SySR) that occurred before July 1, 2025. Therefore, Members should retain records of past transactions and due diligence in case of inquiries”, the Club said
The key changes mean that certain transactions are now permissible without prior OFAC authorization, including:
- Business with Syrian financial institutions (e.g., the Central Bank of Syria), unless otherwise blocked;
- Exports of U.S.-origin food and medicine without requiring a specific OFAC license;
- Humanitarian and reconstruction-related activities that no longer fall within the scope of existing sanctions;
- Transactions previously covered by Syria GL 25, which may still be relied upon where relevant, though many of its authorizations are now redundant.
American Club members were encouraged to:
- Screen counterparties against the current SDN List (many former designations have been removed, but new ones have been added under EO 13894);
- Investigate the ownership structure of entities involved in related transactions, to determine if ownership by blocked persons renders the counterparty implicitly sanctioned under OFAC’s 50% rule;
- Stay updated on the Department of Commerce export controls, which continue to apply to many categories of goods despite OFAC’s revocations;
- Keep records of all due diligence steps and findings in case of future audits or inquiries.
OFAC has emphasized that licence requests and compliance inquiries related to humanitarian activity remained a priority.
Background
On June 30th President Trump issued an EO providing for the revocation of Syria sanctions, effectively unblocking hundreds of individuals and entities on the List of Specially Designated Nationals and Blocked Persons (SDN List), and relaxing certain restrictions on exports to Syria – effective immediately.
The US Treasury said that positive developments in Syria over the past six months had “transformed” the circumstances that gave rise to the former sanctions programme.
The June 30 EO amended EO 13894, preserving and expanding OFAC’s ability to sanction former Syrian president Bashar al-Assad and his associates, human rights abusers, Captagon traffickers, persons linked to Syria’s past proliferation activities, ISIS and Al-Qa’ida affiliates, and Iran and its proxies.
Accordingly, the OFAC Syria-related sanctions program has now become the Promoting Accountability for Assad and Regional Stabilization Sanctions (PAARSS) program.
The six EOs that formed the foundation of the Syria sanctions programme (SySR) have been revoked. Consequently, OFAC will be removing the SySR from the Code of Federal Regulations (CFR).
The EO terminated were
- EO 13338 of May 11, 2004;
- EO 13399 of April 25, 2006;
- EO 13460 of February 13, 2008;
- EO 13572 of April 29, 2011;
- EO 13573 of May 18, 2011;
- EO 13582 of August 17, 2011.
Pending or future OFAC investigations or enforcement actions related to apparent violations of the SySR that occurred prior to July 1st 2025, may still be carried out.
OFAC’s General License (GL) 25, which previously allowed certain otherwise prohibited transactions under the now-revoked Syria Sanctions Regulations (SySR), may still be relied upon where needed. However, many of its provisions are now redundant following the June 30th EO. Persons may also continue to rely on the related Syria GL 25 Fact Sheet issued on May 28th 2025 (now updated to include language regarding the June 30 EO).
As of July 1st 2025 US-origin food and medicine can be exported to Syria without an OFAC licence.
Anyone may send US-origin food or medicine to Syria without a specific OFAC license. That said, the Department of Commerce maintains jurisdiction over the export of most items to Syria. American Club said that members should consult the BIS website for updates.
OFAC has removed hundreds of individuals and entities from the SDN List sanctioned under the Syria sanctions programme.
All property and interests in property of such individuals and entities are unblocked.
A full list of the individuals and entities unblocked is on OFAC’s June 30th Sanctions Lists Update, or OFAC’s PDF outlining Changes to the SDN List, starting on page 1805.
Included in the list of unblocked entities are Syrian financial institutions, such as the Central Bank of Syria. US persons may now provide financial services to Syria, process payments involving Syrian banks, and engage with the new Syrian government, provided none of the parties remains on the SDN List. This includes the use of US dollars for compliant transactions.
The Financial Crimes Enforcement Network issued exceptive relief in late May 2025 allowing US banks to maintain correspondent accounts with the Commercial Bank of Syria.
OFAC has designated additional individuals and entities affiliated with the previous
regime under EO 13894. This list of newly-designated individuals includes former officials and enablers of the Assad regime, persons threatening the peace, security, and stability of Syria, persons associated with Captagon, and other persons associated with SDNs.
Additional targeted sanctions reforms in the June 30th EO
- a) Caesar Act (Temporary) Suspension: The State Department will now consider pausing the enforcement of some or all sanctions under the Caesar Syria Civilian Protection Act of 2019, which imposed sweeping penalties on anyone supporting Assad’s regime or engaging in reconstruction efforts seen as legitimizing it.
- b) Export Controls: The U.S. will no longer require certain export control measures under the Syria Accountability and Lebanese Sovereignty Restoration Act (2003), and the Chemical and Biological Weapons Control and Warfare Elimination Act (1991) (CBW Act). This means companies may now apply for export licenses with a higher chance of approval, particularly for items that could support reconstruction or civilian needs. However, sensitive goods (like dual-use technologies) may still face scrutiny.
- c) Counterterrorism and SST Designations: The June 30 EO directs the Secretary of State to review the designation of Syria as a State Sponsor of Terrorism (SST), and directs appropriate action be taken with respect to the designation of the group Hay’at Tahrir al-Sham as a Specially Designated Global Terrorist (SDGT) and Foreign Terrorist Organization (FTO).
- d) Assistance Restriction and Sanctions Waiver: The June 30 EO also eases restrictions by the CBW Act on Syria concerning foreign assistance, U.S. government-backed credit, and other financial assistance and credit from U.S. financial institutions.