Karam Shaar Advisory LTD

Caesar Act Sanctions: Current Status

Key Developments

  • On 9 October 2025, the 119th US Senate passed S 2296: The National Defense Authorization Act (NDAA) for Fiscal Year 2026 by a bipartisan vote of 77–20.
  • The bill includes several foreign policy provisions, among them two amendments concerning the Caesar Syria Civilian Protection Act of 2019 (116th, Caesar Act), the most stringent set of sanctions ever imposed on the country.
    • Amendment 3662 – Repeal of the Caesar Act, introduced by Senator Jeanne Shaheen (D-New Hampshire), calls for a full repeal of the Caesar Act, effectively removing all statutory sanctions authorities established under that law.
      • The amendment aims to facilitate Syria’s post-conflict recovery and open the way for international reconstruction and private-sector engagement.
      • Proponents argue that maintaining the Caesar framework hinders humanitarian operations and economic recovery, while opponents warn that repeal would eliminate one of Washington’s few remaining tools of leverage over the Syrian government and undermine accountability.
    • Amendment 3899 – Post-Repeal Certification Requirements, sponsored by Senators Lindsey Graham (R-South Carolina) and co-sponsored by Senator Chris Van Hollen (D-Maryland), was initially drafted to suspend—but not repeal—the Caesar Act, replacing it with a new conditional certification regime. However, as introduced on the Senate floor (via Senator Wicker on Graham’s behalf), the amendment was modified to apply following the Act’s repeal, requiring continued executive reporting and oversight after sanctions are lifted.
      • Under this amendment, the President must report to Congress every 120 days on whether the Syrian government meets six specified conditions: (a) cooperation against ISIS, (b) protection of minorities, (c) cessation of support for terrorist groups, (d) withdrawal of foreign fighters from Syrian government and security institutions, (e) peaceful regional conduct, including with Israel, and (f) credible investigations into human-rights abuses committed after December 2024.
      • If the Administration fails to certify compliance for two consecutive reporting periods, the sanctions would automatically “snap back.”
      • The amendment thus evolved from a suspension proposal into a post-repeal oversight framework, described by proponents as a compromise measure balancing economic recovery and humanitarian relief with continued congressional leverage over Damascus.
  • As of 15 October 2025, the enrolled NDAA text reflecting the final amendment language has not yet been published on Congress.gov. References to the Caesar Act’s “repeal” versus “suspension” are therefore based on the official Senate floor transcript and have been corroborated by sanctions specialist Chad Brand, pending release of the final bill.

Implications

  • 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, with the Secretary of State required to certify that each renewal serves US national security interests.
  • However, this six-month renewal cycle has created investor uncertainty, discouraging long-term commitments in Syria due to the risk of sudden policy reversals. Because the Caesar Act is a statutory sanction, only Congress has the authority to repeal it outright.
  • The Senate’s inclusion of the repeal amendment in its NDAA version significantly raises the likelihood of repeal, as it now forms part of a must-pass bill rather than a standalone proposal.
  • At the same time, the Graham–Van Hollen amendment—originally drafted to suspend, but not repeal, the Caesar Act and replace it with a conditional certification regime—was later modified on the Senate floor to apply following the Act’s repeal. The revised language establishes a post-repeal certification framework requiring the Administration to submit regular reports on Syria’s conduct and allowing sanctions to “snap back” automatically if the specified conditions are not met. This adjustment indicates continued bipartisan interest in maintaining congressional oversight and leverage over Damascus even as formal sanctions authorities are lifted.
  • 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. The conference committee’s final bill will determine whether the repeal language survives, and both chambers must subsequently approve that unified version before it can be sent to the president for his signature.
  • Because the House remains out of session amid the ongoing government shutdown, the timeline for conference deliberations is uncertain. However, the Caesar-related provisions may not be a central point of contention compared with higher-priority disputes over funding and oversight, suggesting that any delay will stem from broader political gridlock rather than opposition to this section.
  • Notably, the Senate amendment also includes a provision urging the Administration to explore reopening the US Embassy in Damascus, signaling a potential shift in Washington’s posture toward engagement with Syria.
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