On August 24, 2026, pursuant to Executive Order 14312, the U.S. Department of State took action to rescind Syria’s designation as a State Sponsor of Terrorism (“SST”). Additionally, the State Department and U.S. Department of the Treasury concurrently removed Hay’at Tahrir al-Sham’s (“HTS”) designation as a Specially Designated Global Terrorist (“SDGT”) organization and Specially Designated National (“SDN”), respectively.
Syria’s removal from the SST list eliminated what the Trump Administration describes as the “final major barriers” for private sector investment in Syria. Following these actions, the Office of Foreign Assets Control (“OFAC”) revoked Syria General License 25, which authorized certain transactions despite HTS’ role in the Syrian Government, finding the General License to be no longer necessary.
The Departments of State, Treasury, and Commerce also updated the Tri-Seal Advisory to reflect the recission of Syria’s SST designation. The advisory reinforces that list-based sanctions remain on former Syrian President Bashar al-Assad and his associates, human rights abusers, Captagon drug traffickers, and other destabilizing regional actors who remain on OFAC’s SDN List.
While the Commerce Department has eased licensing requirements for some dual-use exports, including items classified as EAR99 under the U.S. Export Administration Regulations (“EAR”), other restrictions remain, and applications for exports of dual-use items to Syria are continuing to be reviewed on a case-by-case basis. Removal of Syria from the SST list will likely lead to further adjustments to the EAR.
The Husch Blackwell International Trade and Supply Chain team continues to monitor developments related to U.S. sanctions and will provide updates as they become available. If you have questions, please contact your Husch Blackwell attorney.