By Vittorio Maresca di Serracapriola and Natasha Hall

Issue 3: November 2025 

At a Glance

• UN Removes al-Sharaa and Khattab From Terror List — The Security Council delisted Syria’s interim president and interior minister from the UN 1267 regime.
• Washington Drops SDGT Designations for al-Sharaa and Khattab — One day after the UN vote, OFAC removed al-Sharaa and Khattab from the SDN list.
• US Publishes Tri-Seal Advisory on Sanctions Relief — Treasury, State, and Commerce released a unified advisory clarifying eased sanctions, export controls, and permissible business activity in Syria.
• Senate Bid to Repeal Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 (SALSA) and the Syria Human Rights Accountability Act of 2012 (SHRAA) — Senator Shaheen introduced legislation to strike down two core statutory pillars of US sanctions on Syria. 
• Caesar Act Suspension Renewed as Repeal Advances — The State Department issued another 180-day waiver while Congress negotiates full repeal through the FY2026 National Defense Authorization Act (NDAA). 
• US House Approves Syria Terrorism Threat Assessment Act — The House approved the Syria Terrorism Threat Assessment Act, mandating a Department of Homeland Security (DHS) review of individuals in Syria with ties to foreign terrorist organizations (FTOs) and specially designated global terrorist (SDGT) networks. Senate approval is still pending. 
• IMF Holds High-Level Meetings with Syrian Authorities — International Monetary Fund (IMF) leadership held meetings in Washington and conducted a staff visit to Damascus, signaling renewed engagement on Syria’s banking and payment-system recovery.
• UK publishes Syria Trade and Export Guide — The UK Department for Business and Trade published a new business guidance portraying Syria as a high-return frontier market.

Contents 

Recent Developments

UN Security Council Removes al-Sharaa and Khattab from its Sanctions List 

The United Nations Security Council adopted a resolution on 6 November removing Syria’s Interim President Ahmad al-Sharaa and Interior Minister Anas Khattab from the UN 1267 sanctions list, which targets individuals associated with al-Qaeda and of the Islamic State of Iraq and the Levant (ISIL). Fourteen members voted in favor, while China abstained. China’s UN Ambassador Fu Cong argued that the resolution failed to address Beijing’s concerns about Syria’s counterterrorism and security environment. Sharaa and Khattab were added to the ISIL (Da’esh) and al-Qaeda sanctions regime in 2013 and 2014 for pledging allegiance to al-Qaeda, although both later renounced it and fought against it.

CONTEXT AND ANALYSIS: On 9 October, the US reportedly circulated a draft resolution that would delist Sharaa, Khattab, and Hay’at Tahrir al-Sham (HTS) from the UN sanctions list and allow the transfer of financial assets and economic resources to Syria’s central government. The move would deter banks from imposing excessive restrictions on their interactions with the state even while listed individuals were still serving. In addition, the resolution included a targeted exemption to the arms embargo to enable the International Atomic Energy Agency, the Organisation for the Prohibition of Chemical Weapons, and de-mining organizations to operate in Syria without breaching sanctions on dual-use goods. 

Negotiations dragged on for months. China raised concerns that the Council was moving too quickly without securing concrete counterterrorism achievements from Sharaa. Beijing remains concerned about the Eastern Turkistan Islamic Movement in Syria (Uyghur fighters from China and Central Asia fought alongside HTS against Assad). China views them as a direct national-security threat. Many Uyghurs maintain close ties to Syria’s new leadership and have been integrated into the newly established 84th division of the Syrian army despite remaining under UN sanctions.

In early November, under White House pressure to secure the delisting before Sharaa’s state visit, US diplomats submitted a revised text limited to removing Sharaa and Khattab from the sanctions list and pushed for an immediate vote. The Trump administration sought to signal goodwill while avoiding the optics of welcoming a UN-designated terrorist, particularly as the visit focused on Syria joining the US-led global coalition against ISIL. By narrowing the proposal, Washington won broad Council support and Beijing simply abstained. Russia’s UN Ambassador Vassily Nebenzia said Moscow backed the succinct resolution because it reflects the interests and aspirations of the Syrian people.

Delisting Sharaa and Khattab marks a significant step toward bolstering the international legitimacy of Syria’s new government, but it does little to loosen the technical and financial constraints shaping Syria’s reconstruction prospects. HTS and several of its members remain sanctioned, which will continue to deter investors and banks from engaging with the interim administration—particularly given that roughly one-third of it consists of former HTS members.

US Drops SDGT Designations for al-Sharaa and Khattab 

The US Treasury Department’s Office of Foreign Assets Control—the agency responsible for enforcing economic sanctions—removed Interim President Ahmad al-Sharaa and Interior Minister Anas Khattab from its Specially Designated Nationals list on November 7. Sharaa and Khattab were listed as Specially Designated Global Terrorists (SDGTs), a designation the US uses to designate entities and individuals who have committed—or pose a significant risk of committing—acts of terrorism. 

CONTEXT AND ANALYSIS: The US relies on two main tools to designate terrorist entities: the Foreign Terrorist Organization (FTO) designation under the Immigration and Nationality Act, and the SDGT designation under Executive Order 13244, which targets a broader range of actors, including financiers and front companies. 

In July, the Trump Administration revoked the FTO designation of al-Nusrah Front, also known as Hay’at Tahrir al-Sham (HTS). The revocation took effect on 8 July, following the group’s announced dissolution and the interim government’s pledge to combat terrorism in all its forms. 

US officials initially removed the FTO designation while keeping the SDGT designation in place in order to remain compliant with UN sanctions on HTS leadership and to retain leverage over HTS figures while limiting potential congressional backlash.

Under Chapter VII, Article 41 of the UN Charter, the US is required to implement UN-mandated sanctions. As a result, Washington waited to delist Sharaa and Khattab until one day after the United Nations removed them from its sanctions list on November 6. The UK followed suit on November 7. 

 

US publishes Tri-Seal Advisory on Sanctions and Export Controls Relief for Syria 

On 10 November, the US Department of Commerce, the US Treasury Department’s Office of Foreign Assets Control, and the US State Department issued a Tri-Seal Advisory titled “Sanctions and Export Controls Relief for Syria.” The Advisory outlines how the three agencies have eased sanctions and export controls on Syria dating since 13 May 2025. Their actions include: 

1. ending the Syria Sanctions Regulations on 30 June 2025
2. issuing General License 25
3. waiving the Syria Accountability Act for items on the Commerce Control List
4. revoking the FTO designation of al-Nusrah Front (also known as Hay’at Tahrir al-Sham or HTS)
5. issuing waivers under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 to allow foreign assistance, US government credit, exports of specified goods and technology, and loans and credit from US financial institutions to the Syrian government
6. publishing the Commerce Department’s 2 September Final Rule
7. removing Syrian President Ahmad al-Sharaa and Interior Minister Anas Hassan Khattab from the Specially Designated Global Terrorist list on 7 November.

CONTEXT AND ANALYSIS: The advisory, released the same day Donald Trump hosted Syrian President Ahmad al-Sharaa at the White House, sets out the scope of permissible business with Syria. A Tri-Seal Advisory is intended to clarify the US sanctions posture on a specific jurisdiction or sector; guide banks, companies, and foreign governments through rapidly changing rules; signal political intent—in this case, to encourage engagement with Syria; or curb overcompliance by reducing uncertainty about what regulations allow. The advisory signals that Washington views regulatory clarity and consistent messaging across multiple agencies as equally important as sanctions relief.

Whether these assurances succeed will depend on whether international actors view the guidance as durable policy and on tangible improvements in security and transparency.

 

Senator Shaheen introduces a bill in Congress to repeal the Syria Accountability Act and the Syria Human Rights Act

Jeanne Shaheen (D-NH) introduced S. 3172, a bill “to repeal certain Acts that impose sanctions upon Syria,” in the Senate on 10 November. The bill seeks to repeal two major statutory sanctions regimes: the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 (SALSA) and the Syria Human Rights Act of 2012 (SHRAA). Senators Markwayne Mullin (R-OK) and Joni Ernst (R-IA) co-sponsored Shaheen’s bill, which now sits before the Senate Foreign Relations Committee. 

CONTEXT AND ANALYSIS: Congress enacted SALSA on 12 December 2003 to advance four stated goals related to Syria: 

• Ending what Washington viewed as the country’s support for terrorism 
• Compelling Damascus to withdraw its forces from Lebanon after its presence since 1990
• Halting its pursuit of weapons of mass destruction
• Stopping the Assad regime’s illicit import of Iraqi oil and transfer of military items to anti-US forces in Iraq. 

Under SALSA, the US government described Syria as a violator of several UN Security Council resolutions and a state pursuing policies that undermine international peace and security. The Act states that Syria should not have been permitted to serve on the Security Council or to preside over it, and should be removed from it. 

Key SALSA restrictions remain active. These include: 

• A ban on US business investment or operations in Syria¹
• Travel restrictions on Syrian diplomats, limiting movement in Washington DC and New York to a 25-mile radius ²
• A ban on takeoff, landing, or overflight in the US by Syria-owned or -controlled aircraft ³
• Reduced diplomatic contacts with Syria except when needed to protect US interests ⁴
• Blocking of Syrian government property and interests within US jurisdiction  ⁵

In June, the Trump administration issued Executive Order 14312, “Providing for the Revocation of Syria Sanctions,” invoking a waiver for several SALSA provisions. The order waived subsection (a)(1) of the Act, which bans the export of items on the Commerce Control List (CCL) ⁶ , and subsection (a)(2)(A), which bans the export of US products to Syria other than medicine and food. The administration framed the waiver as a narrow measure enabling controlled trade in sectors essential to Syria’s reconstruction and basic services. 

Congress passed SHRAA in 2012 in response to Damascus’ media suppression and widespread human rights violations following the March 2011 uprisings. The Act created four layers of sanctions on: 

• Anyone responsible for or complicit in abuses against Syrian citizens or their families
• Transfers of goods or technologies likely to enable human rights abuses
• Persons who engage in censorship or repression, including restrictions on the free flow of information.
• Anyone who transfers—or helps transfer—goods, technologies ⁷, or services that the US President deems likely to facilitate Syrian government abuses. It also authorizes sanctions on anyone who obstructs access to unbiased information within Syria. 

For SHRAA termination, the President must certify to Congress that Syria has either a democratically elected, representative government or a legitimate transitional authority. The President must also certify that the Syrian government has met extensive conditions. ⁸

The Act allows a suspension of up to 180 days if the President certifies that the Government of Syria is democratically elected and representative of the people of Syria, or if a legitimate transitional government of Syria is in place. 

Much public commentary has focused on the Caesar Act as the primary obstacle to financial re-engagement with Syria. However, even if Congress repeals the Caesar Syria Civilian Protection Act, SALSA and SHRAA would likely continue to block large-scale reconstruction finance, investment, banking engagement, and trade. 

Repealing SALSA would remove a core legal instrument that links Syria’s sanctions to its State Sponsor of Terrorism (SST) designation. While the bill does not directly address SST status, eliminating SALSA could ease the pathway toward eventual delisting by stripping away statutory language that frames Syria as a persistent supporter of international terrorism.

Similarly, repealing SHRAA would eliminate the human-rights-based sanctions framework that currently restricts technology transfers, information-related services, and a wide range of commercial activities. The Act is partly redundant, as other tools—such as the Global Magnitsky Act—offer more targeted mechanisms to address such abuses.

Shaheen’s bill also aligns with recent US government guidance on the “Syria Peace and Prosperity” license issued by the Department of Commerce. That advisory signaled Washington’s intention to reopen certain export channels and ease the long-standing “policy of denial” under the Export Administration Regulations. 

In the Senate Foreign Relations Committee, however, the main resistance to S. 3172 is likely to center on deeper unease about Syria’s post-Assad leadership and the legal spillovers of the bill itself. Senators Jim Risch (R-ID), Ted Cruz (R-TX), John Cornyn (R-TX) and Dave McCormick (R-PA) have signaled skepticism toward any broad sanctions rollback while figures such as Ahamad al-Sharaa—a former al-Qaeda operative—remain central to the new power structure. A further point of contention is that the Syria Human Rights Act of 2012 is not a standalone law but is embedded within the single, consolidated statute known as the Iran Threat Reduction and Syria Human Rights Act. Repealing the SHRAA Act therefore entails rolling back Iran-related sanctions authorities at the same time. 

On the Democratic side, Chris Van Hollen (D-MD) may seek to maintain a conditions-based stance, insisting that human-rights benchmarks and clear guarantees accompany any statutory repeal.

 

US Extends Caesar Act Waiver as Congress Weighs Full Repeal 

On 6 November, the US Department of State suspended the Caesar Act for a second time, issuing another 180-day waiver. The sanctions relief falls under Section 7432(b)(1) of the Caesar Syria Civilian Protection Act of 2019, which allows the President to issue a waiver if doing so serves US national security interests. 

CONTEXT AND ANALYSIS: Since 23 May 2025, the Secretary of State and Secretary of the Treasury have exercised a six-month waiver of the Caesar Act sanctions. The waiver must be renewed biannually by the President, with the Secretary of State required to certify that each renewal serves US national security interests. This six-month renewal cycle has created investor uncertainty, discouraging long-term commitments in Syria due to the risk of sudden policy reversals.

On 9 October, the US Senate passed an amendment to the National Defense Authorization Act (NDAA) for Fiscal Year 2026 asking for full-repeal of the Caesar Act. The Caesar Act is a statutory sanction; only Congress has the authority to repeal it outright. The amendment establishes a post-repeal certification system that obliges the administration to submit regular reports on Syria’s conduct and allows sanctions to be reimposed if Syria fails to meet specified conditions. The NDAA, including the Caesar Act repeal amendment, now proceeds to the bicameral conference committee, where House and Senate negotiators will reconcile differences between their respective versions. 

A US State Department spokesperson reportedly said the Trump administration supports repealing the Caesar Act sanctions on Syria through the NDAA. The US government appears to be in lockstep with this position. Following their closed-door meeting, the US Treasury Department announced a 180-day extension of its suspension of Caesar Act enforcement.

On 6 November, the US Department of State formally stated for the first time that the Syrian government has met the original criteria for suspending Caesar Act sanctions. This announcement sends a positive signal to Congress at a critical moment, as the conference committee works to finalise the NDAA and its repeal amendment.

President Ahmad al-Sharaa also met Representative Brian Mast (R-FL21), a key figure whose support is crucial for advancing the Caesar Act’s repeal. Mast has been one of the main obstacles to the effort. After their meeting, however, he issued a positive statement, noting that he and Sharaa “broke bread” and had a long, serious conversation about how to build a future for Syrians free of war, ISIS, and extremism. Reports suggest Mast will support the repeal of sweeping sanctions on Syria and has signed off on the Caesar Act amendment.

 

US House Approves Syria Terrorism Threat Assessment Act for Senate Consideration

The Syria Terrorism Threat Assessment Act of 2025 (H.R. 1327) passed the House of Representatives on 19 November. It has now moved to the Senate, where it has been referred to the Committee on Homeland Security and Governmental Affairs. Representative Morgan Luttrell (R-TX08) introduced the bill on 13 February, joined by Representative Andrew Ogles (R-TN05), Representative August Pfluger (R-TX11), and Representative J. Luis Correa (D-CA46). The Act instructs the Secretary of Homeland Security to conduct a threat assessment of terrorist threats to the US posed by individuals in Syria with an FTO or a SDGT affiliation. 

CONTEXT AND ANALYSIS: The Committee on Homeland Security’s report on H.R. 1327 highlights two forces driving the Act’s introduction in Congress: the 4.7 million Syrians registered as refugees as of January 2025, and the high number of Syrians the Department of Homeland Security (DHS) categorizes as Special Interest Aliens, individuals whose travel patterns may flag national security risks. DHS argues that it needs a comprehensive assessment of these individuals and networks to safeguard the US from potential terrorist threats. The assessment would also help DHS and Congress determine whether policy or procedural changes are necessary to mitigate identified risks. 

As Executive Order 14312 dismantles the traditional sanctions scaffolding, H.R. 1327 strengthens an intelligence-driven framework capable of sustaining recalibrated pressure, but only on individual Syrians. This comes in the broader context of the US applying increased pressure across immigration enforcement. A DHS-led threat assessment would form the evidentiary basis for a redesigned, targeted sanctions regime, should individuals in Syria be shown to retain operational links to FTOs or SDGTs.

 

IMF Holds High-Level Meetings with Syrian Authorities

The International Monetary Fund (IMF) Managing Director Kristalina Georgieva met Interim President Ahmad al-Sharaa in Washington on November 9. A week later, an IMF staff team visited Damascus (10–13 November) to assess Syria’s economic situation, discuss the authorities’ fiscal and financial sector reform priorities, and review ongoing technical-assistance needs. During the meetings, IMF staff said they would provide technical assistance to help rehabilitate Syria’s payment and banking systems so the financial sector can process safe, efficient payments and banks can resume their central role in financial intermediation and economic recovery. 

CONTEXT AND ANALYSIS: For sanctioned countries attempting to reconnect with the global financial system, IMF engagement often becomes a tacit precondition for meaningful re-entry into the global economy. Even when sanctions ease, banks, donors, and private investors tend to remain cautious, especially when reputational and compliance risks persist. IMF engagement signals that the authorities are open to external scrutiny and that macroeconomic data are accessible.

Years of isolation severed correspondent-banking ties, hollowed out compliance structures, and pushed most transactions into hawala and cash networks, leaving Syrian banks far from Financial Action Task Force (FATF) standards and international expectations. In other post-sanctions contexts, the IMF has often intervened early to rebuild supervisory capacity, restore payment systems, and bring banks back in line with global AML/CFT norms. If the IMF follows these meetings with structured capacity-building—helping the Central Bank of Syria enforce due-diligence rules, strengthen internal controls, and align private banks with Wolfsberg and FATF principles—it could accelerate the reopening of correspondent channels and give donors, investors, and financial institutions the confidence to return. 

There are already signs of movement: Bank Bemo Saudi Fransi has reconnected its banking channels with Saudi banks after nearly 15 years of suspension. Backed by the Saudi Ministry of Investment, the bank recently completed the first transfer from Syria to Saudi Arabia.

Whether this initial staff engagement evolves into more structured IMF monitoring will influence how far sanctions easing translates into real economic effects. An eventual Article IV consultation—the IMF’s annual economic check-up in which it assesses a country’s policies and offers recommendations—would not be transformative on its own, but it would give donors and international financial institutions a clearer, internationally recognized framework to operate under tight compliance constraints. 

 

UK Department for Business and Trade Publishes Syria Trade and Export Guide

The UK Department for Business and Trade published guidance on 4 November for UK companies interested in doing business in Syria. The guidance describes Syria as a “potentially high-return market” despite its challenging and high-risk environment. It highlights several benefits for UK exporters: a new government that aims to attract foreign private investment and accelerate public-sector reform; a market that values British goods and services; and the rapid return of Syrians after more than a decade of war, which could boost economic output. 

Notably, the guidance does not list sanctions among the core commercial “challenges” to doing business, although a later legal section explicitly reminds firms that they must comply with UK sanctions. The document identifies short-term commercial opportunities in large-scale deals with the Government of Syria or its representatives to address urgent national needs. 

CONTEXT AND ANALYSIS: On 24 April, the UK lifted sanctions on several sectors, including trade, finance, transport (aviation), and energy production, while maintaining measures that hold Bashar al-Assad and his associates accountable. It also removed sanctions from entities previously linked to the Assad regime, including the Central Bank of Syria, the Syrian Ministry of Defense and Interior, and leading energy and media companies. The UK justified these changes as a way to enable essential investment and help Syrians rebuild their country and economy. 

By issuing practical guidance for UK firms, the Department for Business and Trade signals that Syria’s risk environment has shifted enough to justify actively supporting trade rather than restricting it. The move aligns with broader international trends, as the US and EU have also eased aspects of their Syria sanctions, marking a tentative phase of economic reintegration. The publication of this guide suggests the UK is positioning itself early in the potential “post-sanctions” reconstruction and trade wave in Syria. The UK’s provision of business guidance indicates that the trade sanctions firewall is considered loosened enough to warrant active outreach. It remains to be seen how UK banks, insurers, and export financiers will respond. 

1.  Section (a)(2)(B)
2.  Section (a)(2)(C). On November 10, Foreign Minister Asaad Shaibani announced on X that Syria had received a decision from the US Secretary of State lifting all legal measures previously imposed on the Syrian Mission to the United Nations and the Syrian Embassy in Washington. However, no corresponding US government document has been released, and the decision Shaibani referenced does not appear in the public record.
3. Section (a)(2)(D)
4. Section (a)(2)(E)
5.  Section (a)(2)(F)  
6.   The Commerce Control List is a detailed index of items that are subject to US export restrictions due to national security, foreign policy, anti-terrorism, or non-proliferation concerns. These items are broadly categorized into ten areas, including electronics, aerospace, computers, and telecommunications. Each item on the list is assigned an Export Control Classification Number (ECCN), which determines the level of control and the need for licensing. 
7. These include firearms or ammunition, rubber bullets, police batons, pepper or chemical sprays, stun grenades, electroshock weapons, tear gas, water cannons, or surveillance technology; or sensitive technology including hardware, software, telecommunications equipment, or any other technology that the President determines is to be used specifically to restrict the free flow of unbiased information in Syria.

8.  These conditions include: unconditional release of all political prisoners; ending violence, unlawful detention, torture, and abuse of citizens of Syria engaged in peaceful political activity; ceasing procurement of technology used to restrict free expression; ending support for FTOs (e.g., Hamas, Hezbollah, Palestinian Islamic Jihad) and barring them from operating on Syrian territory; ending development and deployment of ballistic missiles; halting all WMD-related activities and providing credible assurances of non-repetition; allowing the UN and other international observers to verify compliance.