General License 25 effectively suspends OFAC sanctions targeting Syria. Stringent US export control restrictions on exports and reexports to Syria remain.
By Les P. Carnegie, Damara Chambers, Charles Claypoole, Andrew P. Galdes, Robert Price, Eric S. Volkman, Ruchi G. Gill, Amaryllis Bernitsa, Monica Calce, Matthew Crawford, Eric Green, Matthew R. Gregory, Joelle Hageboutros, Margaret Hynds, Thomas F. Lane, Juan Miramontes, Katherine Ryan, C.J. Rydberg, and Amulya Vadapalli
On May 23, 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License 25 (GL 25), titled “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain Blocked Persons.” GL 25 effectively suspends OFAC sanctions targeting Syria. This comes 10 days after President Trump announced during an appearance at the Gulf Cooperation Council summit in Riyadh, Saudi Arabia, that he was “ordering the cessation of sanctions against Syria to give them a fresh start.” Calling the sanctions “really crippling” and “very powerful,” President Trump stated that easing sanctions against Syria would give the country “a chance for greatness.”
Treasury explained in a press release accompanying the general license that GL 25 “is intended to help rebuild Syria’s economy, financial sector, and infrastructure, in line with US foreign policy interests.” Treasury indicated that the sanctions relief is contingent on the new Syrian government safeguarding its religious and ethnic minorities and not offering safe harbor to terrorist groups. The US government will monitor Syria’s progress toward these goals. As stated in the press release, the sanctions relief is part of a broader strategy aimed at dismantling the US government’s Syrian sanctions framework established many years ago in response to the abuses perpetrated by the former Bashar al-Assad regime.
In parallel, the US Department of State issued a 180-day waiver of mandatory “Caesar Act” sanctions to facilitate investment in key sectors of the Syrian economy. The Financial Crimes Enforcement Network (FinCEN) also provided relief under the USA Patriot Act, allowing US financial institutions to open and maintain correspondent accounts for the Commercial Bank of Syria (subject to certain restrictions identified in FinCEN’s notice).