Syria Sanctions Monitor: Issue 1

July & August 2025

By Vittorio Maresca di Serracapriola and Natasha Hall

Prepared with the advisory input and expert contributions of Sameer Saboungi (US-Syria Business Council).

This monthly newsletter serves policymakers, experts, humanitarians, and the broader public. It delivers a timely analysis of sanctions on Syria, with a focus on relevance and novelty, to inform the public about existing sanctions and to help economic actors, investors, and institutions navigate Syria’s changing legal and regulatory environment. It offers updates on the evolving sanctions landscape; shifts in US, EU, and UK policies; regional dynamics; and legal developments. The Open Society Foundation funds it as part of a collaboration with Karam Shaar Advisory for the project “A Multifaceted Approach to Easing and Coping with Sanctions on Syria.”

At a glance

White House Ends Broad Syria Sanctions – Executive Order 14312 dismantles decades of US sanctions while keeping pressure on Assad-linked actors, serious human rights abuses, and captagon trafficking.
HTS Delisted as a Foreign Terrorist Organization – The Trump Administration drops FTO status after the group’s dissolution, opening doors for aid and investment.
UN Sanctions Under Review – Washington pushes the UN Security Council to reassess its listings on Syria’s interim leaders.
Congress Pushes Back – A new bill, HR 4427 (119th), seeks to extend Caesar Act sanctions despite White House sanctions relief efforts.
Bipartisan Delegation in Damascus – Senators Shaheen and Wilson call for a full repeal of the Caesar Act on their landmark visit to syria.
Export Controls Eased – The US Commerce Department removes licensing requirements for most US civilian goods, signaling support for early reconstruction.
Google Reopens Syria to Advertisers – The Country has been removed from its sanctions list, creating new opportunities in digital markets.
Currency Gamble with Russia – The Interim Government reportedly turns to sanctioned firm Goznak for banknote printing, raising major compliance risks.

Contents

Recent Developments

White House Issues EO 14312, Ending Broad Syria Sanctions

On 30 June, the White House issued Executive Order (EO) 14312, “Providing for the Revocation of Syria Sanctions,” reshaping the US sanctions framework on Syria. The order ends the US’s comprehensive sanctions program on Syria while keeping targeted measures against Bashar al-Assad, actors associated with the former Assad regime, and other destabilizing actors. The administration framed the policy as continuing its support for a peaceful, stable, and unified Syria under the new Interim Government. President Trump terminated the national emergency declared in EO 13338 (2004), the legal basis for most Syria sanctions regulations issued through several EOs. He revoked a series of these Syria-related EOs issued between 2006 and 2011.¹ As a result, the Office of Foreign Assets Control (OFAC) amended the Code of Federal Regulations on 25 August 2025, to remove the Syrian Sanctions Regulations.

Trump expanded the “Syria-related” national emergency declared in EO 13894 (October 2019), and added three new categories for blocking sanctions under the EO: individuals associated with the former Assad regime; those providing material support for captagon; and those responsible for missing US persons. These additions are alongside the existing categories covering individuals complicit in serious human rights abuses or destabilizing Syria and threatening its territorial integrity. Thus, EO 13894 now houses the remaining Syria-related sanctions and is the main executive authority that continues to block the assets of sanctioned Assad regime-affiliated individuals and entities.

Additionally, EO 14312 invokes a waiver of key provisions of the Syria Accountability Act of 2003 (SAA).²Congress has authorized the president to waive application of the SAA on national interests grounds. On 30 June, Trump waived the provision of the SAA banning most US exports to the country, which would allow US non-humanitarian exports to Syria. The president also waived restrictions previously applicable to Syria in the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991, thereby allowing foreign assistance, US government credit, exports of national security-sensitive goods and technology, and US bank loans to the Syrian government. ³

Finally, although Caesar Act sanctions have been waived for 180 days since 23 May 2025, EO 14312 directs the Secretary of State, in coordination with the Treasury Secretary, to assess whether the Syrian Government now meets the benchmarks of the Caesar Syria Civilian Protection Act of 2019. If they determine that the benchmarks in Section 7431(a) of the Caesar Act are met,⁴the Secretaries may suspend some or all mandatory sanctions under the Act. The EO also mandates a review of major counterterrorism designations still applied to Syria, including reassessing the country’s designation as a State Sponsor of Terrorism (SST) and “taking appropriate action” with respect to the Foreign Terrorist Organization (FTO) designation of HTS and the Specially Designated Global Terrorist Designation (SDGT) of HTS and Interim President al-Sharaa.⁵

CONTEXT AND ANALYSIS: After the collapse of Bashar al-Assad’s regime, the new government led by Ahmad al-Sharaa signaled its willingness to cooperate with the US on counterterrorism. In response, the Trump Administration moved to ease economic sanctions on Syria. On 23 May 2025, it issued General License 25 (GL 25) and waived sanctions under the Caesar Syria Civilian Protection Act of 2019. Unlike General License 24, issued by the Biden Administration in January 2025 shortly after the fall of the Assad regime, GL 25 is not time-barred and remains in effect today. However, even as these measures authorized US persons to engage in many activities otherwise prohibited under the Syria sanctions program, they were a temporary suspension and not a permanent lifting of sanctions. Significant restrictions on trade remained, including comprehensive export controls, as well as asset-blocking sanctions on designated parties.

Just over a month later, EO 14312 effectively ended one of Washington’s most comprehensive sanctions regimes and signaled a shift toward easing stringent export-control restrictions and gradually removing Syria’s SST designation. The full impact of these waivers remains uncertain, as private companies and Western investors have been relatively slow to adjust their compliance policies and procedures and resume business in Syria. Several determinations must be finalized before some changes take effect.

Syria’s designation as an SST, along with the SDGT status of HTS and Interim President Sharaa, remains under review by the Secretary of State. The SST designation implicates certain restrictions on exports and financial transactions and has a broader chilling effect on Foreign Direct Investment (FDI). Even with loosened controls, much sophisticated machinery and technology destined for Syria will still require export licenses, prompting businesses to proceed cautiously, conduct thorough due diligence, and manage ongoing compliance risks. Additionally, multiple sanctioned entities remain active in Syria, including those linked to Iran, Hezbollah, and Russia. Their continued designation under the modified EO 13894 keeps compliance risks high and underscores the need for careful screening and monitoring.

Trump Administration Revokes FTO Designation of HTS

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 Secretary of State Marco Rubio said the decision builds on the momentum of the 30 June Executive Order (EO), “Providing for the Revocation of Syria Sanctions,” and acknowledges the positive steps taken by Syria’s new government under President Sharaa.

CONTEXT AND ANALYSIS: The US uses two main tools to designate terrorist entities: the FTO designation under the Immigration and Nationality Act, and the SDGT designation under EO 13224, which targets a broader range of actors, including financiers and front companies. FTO designations are the strictest, criminalizing nearly all forms of engagement, from financial aid to logistical support. HTS was initially listed as an FTO due to ties with al-Qaeda, but those ties have since dissolved. Despite this, the designation lingered, blocking aid and investment during Syria’s political transition. Removing the FTO status now opens doors for aid, reconstruction, and investment.

Critics argue that the delisting of HTS should have been tied to clear governance benchmarks, such as inclusive politics, respect for human rights, and a commitment to democratic transition. Civil society actors share these concerns, warning that the US risks rewarding Syria’s leadership for its international cooperation while ignoring ongoing domestic abuses.

What these critics overlook is that the Trump Administration still retains significant leverage. The revised EO 13894 allows the administration to impose new sanctions at any time if Syrian authorities fail to cooperate. Additionally, terrorist designations are not intended as tools to enforce human rights or democratization. Other mechanisms, such as the Global Magnitsky Act and the International Religious Freedom Act, offer more targeted ways to hold perpetrators accountable.

The decision to lift the FTO while maintaining the SDGT designation likely reflects two goals: complying with UN 1267 sanctions targeting HTS leadership,⁶and preserving leverage over HTS leadership while providing political cover in case of congressional backlash to the FTO removal. It also likely reflects an incremental approach that the Trump Administration has been taking to easing restrictions on Syria. In practice, HTS remains designated, but lifting the FTO status enables broader recovery and reconstruction efforts, increased foreign investment, and expanded humanitarian and peacebuilding operations, while easing compliance burdens and reducing legal risk—all while signaling that the Interim Government must continue to substantiate its pledges and uphold its commitments.

Washington Pushes UNSC to Review UN Sanctions on Syria’s Interim Leaders

In late July, the US urged the United Nations Security Council (UNSC) to adjust its sanctions on Syria. The US mission to the UN said it is working with Council members to review the Syria-related designations on the UNSC Resolution 1267 sanctions list, which currently names HTS, Interim President Sharaa, and Interim Interior Minister Anas Khattab as sanctioned entities and individuals under measures targeting al-Qaeda and the Islamic State of Iraq and the Levant (ISIL).⁷According to the statement, the Syrian Interim Government has clearly committed to combating al-Qaeda and ISIL, while both groups have openly declared their opposition to the new government and threatened to destroy it.

CONTEXT AND ANALYSIS: HTS, President Sharaa, and Interior Minister Khattab have long been subject to UN counterterrorism sanctions under the 1267 regime, which targets al-Qaeda, ISIL, and their affiliates. Those on the list face an asset freeze, a travel ban, and an arms embargo. Member states must freeze the funds of designated parties and block their nationals from providing financial support.

The UN listed Sharaa (under the name Abu Mohammad al-Jawlani) in 2013 after he pledged allegiance to al-Qaeda. In 2014 it added the al-Nusra Front, HTS’s precursor that fought Assad’s regime, after it pledged allegiance to al-Qaeda. While al-Nusra disassociated itself from al-Qaeda in 2016, and united with other armed groups to form HTS, the Security Council determined that HTS was an alias for al-Nusra and placed the new group under sanctions in 2017. The 1267 list still includes HTS today, even after Sharaa dissolved the group upon taking power in Damascus. Both Sharaa and Khattab remain sanctioned, as do mid-level HTS commanders, small groups of foreign fighters absorbed by HTS, and former al-Nusra members who later broke away.

A UN sanctions monitoring report from July found that “no active ties between al-Qaeda and HTS” were observed since Assad’s fall, though it noted that “many tactical-level individuals hold more extreme views” than Sharaa and Khattab, who are generally seen as “more pragmatic than ideological.”

Since 2016, HTS has publicly disavowed al-Qaeda and its transnational jihadist goals, banning al-Qaeda leaders from operating in its territory. Al-Qaeda has had no operational presence in Syria since 2020, neither holding territory nor conducting military activities.⁸HTS has also taken a harder line against ISIL. It has arrested members, and in some cases executed them publicly, to demonstrate its zero-tolerance stance.

The biggest obstacle to delisting lies with UNSC’s permanent member China. Beijing remains concerned by the Syrian military’s integration of Uyghurs from the Turkistan Islamic Party (TIP), a transnational jihadist group whose stated goal is to establish an Islamic state in Xinjiang and Central Asia. Several TIP militants now hold senior positions in the Syrian Armed Forces, which even created the 84th Division to incorporate Uyghur and other foreign fighters.

Russia shares similar concerns about Chechen and Central Asian fighters, including Uzbek nationals integrated into Syrian ranks. European members also worry that their nationals who fought in Syria might return to spread extremist ideologies, either in person or online, despite HTS having detained many of them over the years.

Sharaa’s decision to grant military ranks to several foreign fighters in the national army—and his proposal to naturalize some of them—has fueled additional unease. While Sharaa argues that these moves help keep foreign fighters under tighter control, many member states remain unconvinced.

US Congress Bill HR 4427 Threatens to Extend Caesar Act Despite Trump’s Sanctions Relief

Representative Michael Lawler (R-New York) introduced HR 4427 (119th Congress) on 16 July 2025 and referred it to the House Committees on Financial Services, Foreign Affairs, and Judiciary. The bill’s most consequential provision keeps the Caesar Act firmly in place, offering only a narrow path to suspension if Syria meets eight conditions for two consecutive years. The bill would also allow for the president to suspend or waive application of the Caesar Act without a 180-day limit. The bill calls for a review of US banking restrictions and sanctions on Syria, strengthening the Syrian central bank’s anti-money laundering (AML) capacity, updating sanctions policy to reflect current conditions, and supporting Syria’s reintegration into the global financial system. While HR 4427 (119th) passed a vote in the House Financial Services Committee, it has not advanced further in the legislative process to reach the floor of the House of Representatives for a vote. The Trump Administration has not formally endorsed any bill, but US Special Envoy for Syria Tom Barrack has backed HR 3941/S 2133 and its clean repeal of the Caesar Act.

CONTEXT AND ANALYSIS: Seven bills related to US sanctions against Syria are currently before Congress, all still at the “introduced” stage. Our forthcoming thematic brief on sanctions will be analyzing and comparing them all. None has passed either chamber, and only two have reached a floor vote. Together, these bills highlight competing visions for US policy toward Syria. They fall into three categories: repeal-focused bills that aim to end the Caesar Act; reform and adjustment bills—such as Rep. Lawler’s—which revise rather than repeal the Act; and security-focused bills that emphasize counter-narcotics and counterterrorism.

HR 4427 (119th) signals a break from the Trump Administration’s current approach. By embedding a two-year monitoring requirement, the bill pushes the Caesar Act’s expiration into 2027 at the earliest,⁹effectively locking Syria into at least two more years of sanctions regardless of compliance. This delay risks undercutting President Trump’s 30 June 2025 Executive Order, which ended broad-based sanctions and sought to open space for reconstruction and refugee return.

Critics, such as the Syrian American Council and the Syrian Emergency Task Force, urged all members of Congress to vote “No” on HR 4427 (119th). They argue that adding new conditions—focused on captagon trafficking and minority protection—is unnecessary and serves to further chill economic recovery efforts and foreign investments in Syria and hamper the Trump Administration’s policy. The US already possesses tools to address these issues through existing mechanisms, including EO 13894, the Magnitsky Act, the Captagon Act,¹⁰and the Illicit Captagon Trafficking Suppression Act of 2023. Similarly, regarding the arbitrary detention of religious minorities, the EO already empowers the US to target human rights violators, and existing authorities under the Magnitsky Act and the International Religious Freedom Act.

The result is a contradictory posture: while the president gains greater waiver flexibility, the Act’s continued existence sends a chilling signal to investors and international partners.

Senator Shaheen and Representative Wilson Visit Syria to Push for Repealing Caesar Act

Senator Jeanne Shaheen (D-New Hampshire) and Representative Joe Wilson (R-South Carolina) visited Syria on 25 August to push for a permanent repeal of US sanctions, which they said were holding back the country’s recovery from a brutal civil war. They led the first official US delegation to enter the country in years.

CONTEXT AND ANALYSIS: The Caesar Act, enacted in 2019, imposed sweeping penalties on Syria’s construction, energy and financial sectors in response to Bashar al-Assad’s atrocities during the civil war. Unlike other sanctions programs, the Caesar Act legislatively mandated secondary sanctions on Assad’s facilitators, targeting not only US persons and entities but also non-US actors involved in reconstruction under Assad.

With Assad gone and an interim government in place, Shaheen and Wilson argue that the sanctions now do more harm than good as they deter foreign investment and stifle reconstruction. They also stress that the Caesar Act was designed to hold Assad and his enablers accountable for war crimes. Continuing to enforce sanctions against a regime that no longer exists risks accusations of inertia and legal overreach—especially if the law continues to obstruct humanitarian aid, reconstruction planning, or financial engagement in key sectors.

President Trump announced temporary relief in May, announcing his intention to cease sanctions on Syria. However, the bill only allows him to issue waivers in 180-day increments. Shaheen and Wilson pushed to attach repeal language to the annual National Defense Authorization Act (NDAA), a must-pass defense bill that the Senate will consider in early September. This approach would allow repeal language to advance even if standalone bills stall in committee. Although the House Rules Committee rejected their proposed amendment, the Senate version of the defense budget bill also included repeal language, the outcome of which remains uncertain.

The bipartisan push by these two lawmakers reflects a broader shift in US policy toward uplifting Syria’s new government and fostering economic recovery. Their visit underscores bipartisan support for a robust US role in the country’s transition.

Still, their efforts remain politically precarious given the nature of the regime change and the reputational risks of a premature repeal. HTS, once an al-Qaeda offshoot, only had its FTO designation lifted in July 2025. Any legislative move that removes sanctions without replacing them with a tailored framework risks being interpreted as acquiescence to formerly designated terrorists now in power.

Blanket repeal may look problematic for certain lawmakers unless paired with new legislation targeting post-Assad threats—particularly HTS’s treatment of minorities, political dissidents, and its overall human rights records. However, expectations for governance in a post-conflict Syria, such as full protection for minorities or robust security guarantees, may sound unrealistic without significant external support. Rebuilding national security institutions will require major outside investment; without it, even well-intentioned local leaders will struggle to prevent abuses or protect vulnerable communities. Moreover, these concerns are adequately addressed with sanctions authorities in EO 13894.

US domestic political dynamics will also shape the debate. Israeli officials, long active in Washington over Syria-related security issues, have repeatedly secured support for measures aligned with their security priorities, including limits on sanctions relief. That momentum slowed after Trump announced the “cessation of sanctions” on Syria, but could return if his focus shifts elsewhere—particularly if minority rights concerns, reignited by the As-Suwayda massacres, continue to dominate headlines.

Bureau of Industry and Security Loosens Syria Export Rules

On 2 September 2025, the US Department of Commerce’s Bureau of Industry and Security (BIS) published a rule that eases licensing requirements for civilian exports to Syria, implementing EO 14312 on the revocation of Syria sanctions. As a result of BIS’s action, US-origin common goods, software, and technology classified as EAR99 under the Export Administration Regulations (typically items with purely civilian uses), as well as consumer communications devices, “mass market” technology and software (including source codes), and certain civil aviation items, can now be exported to Syria without a license. The US still restricts exports that serve military end-uses or enhance Syria’s military potential, mainly due to its SST designation. Exporters must continue to obtain licenses for dual-use items on the Commerce Control List (CCL). BIS now applies a more facilitative standard: it presumptively approves licenses for CCL exports that support commercial end uses, economic development, or the Syrian people (e.g., telecommunications, water, power, aviation, and other civil services). Exports that do not meet these criteria are reviewed case by case to assess consistency with US national security and foreign policy interests, including promoting peace and prosperity in Syria. Restrictions remain on sanctioned actors.

CONTEXT AND ANALYSIS: The 2 September final rule marks the first significant recalibration of US export restrictions on Syria in over two decades. After the 2003 Syria Accountability and Lebanese Sovereignty Restoration Act, Washington imposed a unilateral trade embargo that made civilian trade with Syria almost impossible. This latest move reflects a policy shift signaled by EO 14312, as Washington recalibrates its Syria strategy in the post-Assad environment. By easing licensing requirements for non-sensitive civilian goods, the Department of Commerce is signaling readiness to support early reconstruction efforts, particularly in sectors such as telecommunications, civil aviation, and essential services like power and sanitation. However, the change stops short of lifting restrictions entirely. Export controls will remain firmly in place while Syria remains designated as an SST and while concerns over diversion to sanctioned actors persist. Additionally, banks and logistics firms, wary of secondary sanctions and reputational risks, may continue to over-comply, leaving even authorized transactions stalled.

Operationally, the announcement could reduce transaction costs for firms engaging in non-sensitive exports to Syria. The impact on exports of more sophisticated dual-use goods and technology needed to rebuild Syria will hinge on how quickly and efficiently the BIS processes and approves license applications for these goods. A licensing requirement still imposes a burden on exporters, and without clear timelines, exporters may remain hesitant to trade with Syria, leading to a slower-than-expected rollout of trade flows. Prior to this rule, BIS typically processed licenses under a case-by-case standard of review in 1-2 months, and processing times may now be faster under a presumption of approval standard.

The immediate economic effects will likely be limited but noticeable in specific sectors. Given Syria’s minimal merchandise trade with the US—constrained by geographic distance and a lack of competitive advantages—the most significant near-term gains will come in IT services, software, and digital infrastructure, where US firms have a comparative edge and face lower logistical barriers. That said, compliance risk remains a major hurdle.

For the rule change to have meaningful economic impact, BIS may need to engage more actively with industry stakeholders, provide granular guidance on permissible transactions, and clarify enforcement priorities.¹¹The BIS Rule leaves in place anti-terrorism export controls and prohibitions on items that could enhance Syria’s military, police, or intelligence capabilities. Exports to sensitive end users still require Congressional notification, and all EAR Part 744 end-use and end-user controls remain in force. BIS will need to provide careful guidance to ensure firms can seize this opening without running enforcement risks.

Google Removes Syria from Advertising Sanctions List Amid Easing of US Restrictions

In August, Google updated its Ads Legal Requirements policy and its “Understanding Country Restrictions” help center page to reflect Syria’s removal from the US Treasury’s OFAC sanctions list. The change affects multiple advertising platforms, including Google Ads, Ad Exchange, and Ad Manager. Publishers and advertisers previously restricted by sanctions can now restore their accounts through Google’s standard verification process. Accounts suspended for geographic restrictions need manual review before reactivation. Users who were physically in Syria during the sanctions but maintained accounts registered in unrestricted territories can now access services immediately. The update also makes Syria a targetable location within Google Ads’ geographic targeting options. Campaigns set to “All countries & territories” will now automatically include Syrian users unless campaign managers manually exclude the country.

CONTEXT AND ANALYSIS: Syria’s digital recovery remains severely constrained by platform restrictions that continue to block access to essential online services, despite the formal lifting of most Western sanctions. Many critical digital tools and technologies remain inaccessible from Syrian IP addresses. Google still blocks core services such as Firebase and Google Play, forcing users to rely on unofficial applications.

Historically, Google’s compliance framework flagged seven OFAC-sanctioned territories: Crimea, Cuba, the so-called Donetsk People’s Republic, Iran, the so-called Luhansk People’s Republic, North Korea, and Syria. Companies are required to set up geographic IP-based screens to filter and block services to comprehensively sanctioned jurisdictions. Removing Syria reduces this list to six territories—the first reduction since the policy’s introduction. Until recently, Google Ads classified Syria as an embargoed territory where businesses could neither target users nor run campaigns.¹²Now, with sanctions lifted, Syrian businesses can run targeted campaigns using lookalike audiences and interest-based segments.

Syria’s reintegration into Google’s advertising ecosystem reopens access to roughly 22 million people. Mobile advertising holds particular promise as smartphone adoption continues to rise despite economic pressures. Google’s decision also signals that global technology companies are beginning to align their compliance frameworks with the recent easing of US sanctions, an indicator of how quickly or slowly the private sector may normalize its engagement with post-Assad Syria.

The change also provides an early test of whether sanctions relief can translate into tangible economic gains, such as more dynamic digital markets and greater small-business access to global platforms. The Syrian market now presents opportunities for local businesses seeking to reach domestic audiences and international companies targeting Syrian diaspora communities. This development could drive the growth of digital services, boost e-commerce, and attract advertisers and investors.

However, the update alone will not drive full digital recovery. Key platforms for developers, such as GitHub and GitLab, continue to block Syrian IP addresses, and popular education apps like Duolingo and Coursera remain inaccessible. Whether future steps will focus on user safety and broader access, or remain limited to commercial services, remains to be seen.

Interim Government Reportedly Turns to Sanctioned Russian Firm Goznak for Currency Overhaul

The Syrian Interim Government has reportedly struck a deal with Goznak, the US-sanctioned Russian state-owned money printing firm, to produce new banknotes and remove two zeros from its currency in a bid to restore public confidence in the severely devalued pound. Central Bank Governor Abdelkader called the revaluation a strategic pillar of fiscal and monetary reforms.

CONTEXT AND ANALYSIS: Goznak, Russia’s state-owned enterprise, produces currency, banknotes, and security products like passports. According to the US State Department, it supports the US-designated Federal Security Service (FSB), Russia’s main security agency, and has printed counterfeit currency abroad, including over USD 1 billion worth of counterfeit Libyan banknotes.

The US designated Goznak under EO 14024, issued on 15 April 2021. OFAC targeted Goznak for operating in Russia’s manufacturing sector and being owned by the Russian government. Under OFAC rules, foreign financial institutions (FFIs) that “conduct or facilitate significant transactions” for any EO 14024-designated person, including Goznak, may have their US correspondent and payable-through accounts blocked.

If Damascus tasks Goznak with printing banknotes, it would anchor the country’s monetary operations to a heavily sanctioned Russian enterprise, exporting that risk directly into Syria’s prices and banking sector. For a country trying to rebuild access after the US revoked the dedicated Syria country sanctions program, such a move would undermine the early progress toward reintegration. While Damascus could explore safer alternatives, such as contracting non-sanctioned printers like De La Rue or regional facilities in the Gulf, Goznak remains the fastest option given Russia’s existing printing channels.

Additionally, with most Syria-specific sanctions lifted, reconnecting Syrian banks to the global system depends on FFIs’ risk assessments. Correspondent banks will ask whether supporting a Syrian bank could mean facilitating a significant transaction for an EO 14024-designated person. Since Goznak appears on the US’s Specially Designated Nationals (SDN) list with explicit “secondary sanctions risk,” and is asset-frozen by both the EU and UK, any EU or UK bank must reject transactions involving it.

Most correspondents will extend this caution to the entire Syrian sector, viewing it as indirectly exposed. In practice, this means de-risking: they will exit onboarding, cap limits, withhold USD/EUR clearing, and decline trade-finance instruments whenever they cannot verify that proceeds will not—even indirectly—support the printing arrangement.

Goznak’s history compounds these risks. The firm previously arranged Syrian banknote shipments through opaque third-country intermediaries. Under this system, the former Assad regime received 240 tonnes of banknotes via Cyprus-based companies. Re-creating that model under today’s Russia-sanctions environment would push Syria toward opaque routing, front companies, and non-standard insurance—weakening the auditability of the currency lifecycle from press to vault to ATM.

Conclusion

The past two months have marked a turning point in US sanctions on Syria. The formal end of the comprehensive sanctions program, the delisting of HTS as an FTO, and the relaxation of export rules by BIS signal a decisive shift aimed at further fostering Syria’s recovery and reintegration. These measures open new channels for trade, investment, and humanitarian engagement, with the potential to reshape the country’s economic and political landscape.

Yet the path forward remains fraught. Many companies cite the Caesar Act as one of the primary impediments to their willingness to enter and invest in Syria. Stalled efforts in Congress to repeal the Caesar Act, along with counter-legislation to postpone its termination and impose additional conditions, would reinforce a sanctions framework whose original rationale—the continued presence of the Assad regime—no longer matches today’s realities. Violent sectarian clashes in As-Suwayda governorate in southern Syria have stalled congressional action, and continued political or sectarian violence risks derailing what progress has been made.

The months ahead will be pivotal. The rollout of EO 14312, the review of HTS’s terrorist designation, the reassessment of Syria’s status as an SST, and Ahmad al-Sharaa’s expected visit to the UN in September will help determine the scope and pace of sanctions relief. These developments will send powerful signals to stakeholders weighing deeper engagement with Syria.

These include EO 13399 (2006), EO 13460 (2008), EO 13572 (2011), EO 13573 (2011), and EO 13582 (2011).
In line with section 5(b) of the Syria Accountability Act.
As outlined in the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act).
Under Section 7431(a).
Pursuant to 22 USC 2371, 22 USC 2780, and 50 USC 4813(c).
Interim President Ahmad al-Sharaa and Interim Ministry of Interior Anas Khattab remain listed under the UN 1267 sanctions regime, which the US must enforce under Chapter VII of the UN Charter.
Also known as Daesh.
A number of al-Qaeda figures are laying low in the northwest.
This is assuming that it would take at least one year for HR 4427 (119th) to be adopted.
HR 6265 (117th).
BIS has procedures where a company can seek guidance in advance.
Criterion ID 2760.