On 24 February 2025, the EU enacted its most significant changes to Syria sanctions since 2011, introducing permanent exemptions and suspensions to support Syria’s transition and economic recovery after the fall of the Assad regime in December 2024. The revisions removed four public banks from the sanctions list, allowed limited transactions with the Central Bank of Syria, eased EU-Syria banking restrictions, and lifted bans on importing Syrian oil, exporting energy equipment, and investing in the power sector. Temporary humanitarian aid exemptions were made permanent, and travelers can now bring personal luxury items into Syria, though commercial sales remain prohibited. Reinstating sanctions would require unanimous EU approval, with no automatic snapbacks. However, U.S. secondary sanctions, compliance risks, Syria’s FATF gray-listing, and global “de-risking” continue to deter engagement, limiting the economic impact without broader reforms and regulatory assurances.

Karam Shaar and Vittorio Maresca di Serracapriola analyze how the US terrorist designations and delisting mechanisms interact with UN sanctions. The US has sanctioned Ahmad al-Sharaa, Syria’s Interim President and de facto leader, solely under the Specially Designated Global Terrorist (SDGT) designation. Meanwhile, his group Hay’at Tahrir al-Sham (HTS) holds both an SDGT designation and a Foreign Terrorist Organization (FTO) label. The report examines the comparative stringency of these designations, showing how each imposes severe legal and financial restrictions. It also highlights the interaction between UN and US delistings, noting that unlike listings—mandated by the UN Security Council through Chapter VII resolutions—delistings do not carry the same binding requirement.

Karam Shaar and Benjamin Feve analyze General License 24 (GL24), issued on 6 January 2025, as a U.S. Treasury measure to address Syria’s post-Assad needs. GL24 facilitates targeted transactions for energy provision, personal remittances, and governance, aiming to alleviate humanitarian crises and stabilize essential services. The report highlights successes such as doubling Syria’s electricity capacity and enabling a significant salary increase for public employees. However, it notes key limitations, including the absence of provisions for reconstruction, compliance challenges, and the short six-month duration, which discourages long-term initiatives. The authors emphasize the need for recalibrated sanctions to balance urgent humanitarian needs with sustainable recovery efforts.

This policy brief explores how President Bashar al-Assad is restructuring Syria's economic networks to ensure his access to resources despite the economic collapse faced by the rest of the country. By centralizing control over critical sectors through new economic fronts, Assad is positioning himself as a major economic actor, further entrenching his power while the humanitarian crisis faced by ordinary Syrians worsens. Our analysis sheds light on the inner workings of these networks, offering insights for policymakers aiming to forge a political settlement to the ongoing conflict. Understanding these networks is essential for devising effective strategies to counter the regime's resilience in the face of international pressure.

In 2020, the EU sanctioned Maher al-Imam for his financial support to the Syrian regime, but his appeal was dismissed by the Court of Justice of the European Union in 2021. Despite his reduced public support and withdrawal from formal business dealings, Maher maintains control over key companies linked to the regime through his associate Muhammad Ammar Dalloul. Although, Maher transferred his shares in “Waves” to Dalloul in 2022, he yet still appears to be in control of the company. Last month, the EU delisted Maher without public justification, despite evidence suggesting that both Maher and Dalloul should be sanctioned for their ties to the Assad regime. This delisting exemplifies the failure of Western governments to understand the complex business-regime networks in Syria, highlighting the need for the EU and Western governments to revise their sanctioning processes to enhance their effectiveness while mitigating unintended consequences for innocent civilians.

For further details, you can read the full report here.