By Vittorio Maresca di Serracapriola and Natasha Hall

Issue 2: September & October 2025

At a Glance

• Al-Sharaa Pushes for Full Repeal in Washington – During his historic UN visit, President Ahmad al-Sharaa met senior US officials to call for the permanent repeal of the Caesar Act.

• Senate Approves Repealing the Caesar Act – The US Senate approved language repealing the Caesar Act through the FY2026 National Defense Authorization Act (NDAA), but the measure remains stalled in the House amid ongoing gridlock. 

• OFAC Rebrands Syria Sanctions Framework – The US Treasury renamed its Syria-Related Sanctions Regulations as the Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations, removing Syria from the category of comprehensively sanctioned jurisdictions.

• UN Weighs Sanctions-Easing Proposal – The US has circulated a draft UN resolution that would lift asset freezes and arms-transfer limits on Syria and remove President Sharaa and Interior Minister Khattab from the ISIL and al-Qaeda sanctions list. 

• UK Delists HTS – London removed Hay’at Tahrir al-Sham from its terrorism list to enable direct engagement with Syria’s interim authorities and bolster counterterrorism cooperation. 

• Mastercard Returns to Syria – A new memorandum of understanding between Mastercard and the Central Bank of Syria outlines cooperation on developing a national payments ecosystem to support digital financial inclusion, signaling cautious re-engagement amid ongoing sanctions on the country. 

• Big Tech Re-enters Syrian Market – Apple, Samsung, Zoom, and Meta have resumed operations after export restrictions in the US were lifted under the new Bureau of Industry and Security’s rule.

• US to Review Syria’s State Sponsorship of Terrorism Designation– A six-month review of Syria’s State Sponsor of Terrorism (SST) status is underway, paving the way for delisting early next year or sooner.

Contents

Recent Developments

Al-Sharaa and al-Shibani Press for Caesar Act Repeal During US Visit 

Syrian President Ahmad al-Sharaa urged Washington to lift sanctions imposed under the 2019 Caesar Act during his visit to New York for the UN General Assembly—the first by a Syrian leader in nearly six decades. In New York, al-Sharaa met US Secretary of State Marco Rubio. According to a State Department readout, Rubio emphasized the opportunity to “build a stable and sovereign nation” in Syria following Trump’s announcement of sanctions relief. Al-Sharaa and Foreign Minister al-Shibani also met Senator Jeanne Shaheen, sponsor of a bill to repeal the Caesar Act. Their talks centered on lifting sanctions and repealing the Act as steps toward economic recovery and stronger counterterrorism cooperation.

CONTEXT AND ANALYSIS: Both Republican and Democratic lawmakers have introduced repeal bills, arguing that the Caesar Act has outlived its purpose and now blocks recovery, reconstruction, and humanitarian relief. If Washington limits relief to executive actions—such as general licenses, case-by-case waivers, or the lifting of specific executive orders—while statutory sanctions remain intact, banks and private investors may continue to avoid Syria as a legal risk and price in a “snapback premium,” an added risk cost reflecting the possibility that sanctions relief could be swiftly reversed. 

US domestic politics is likely to shape the debate over repeal. Israeli officials have been lobbying to keep sanctions on Syria in place. That momentum slowed after President Trump announced the “cessation of sanctions” on Syria in May 2025. However, the Israeli government continues to advocate for conditional sanctions relief, rather than a blanket repeal.

Senator Lindsey Graham, a close Trump ally, told Axios that he would back repeal of the Caesar Act if Sharaa’s government advanced a new security deal with Israel and joined the coalition against ISIL. In September, Israel and the new Syrian government were reported to be in talks to reach an agreement. However, with ongoing Israeli airstrikes and the occupation of parts of southern Syria, Sharaa has said Syria joining the Abraham Accords is unlikely due to widespread anger over Israel’s occupation of Syrian territory.

Senate Moves to Repeal Caesar Act and Redefine US Sanctions on Syria 

On 9 October 2025, the 119th US Senate approved S 2296: The National Defense Authorization Act for Fiscal Year 2026,¹ by a bipartisan vote of 77-20. The bill includes several foreign-policy provisions, notably two amendments addressing the Caesar Syria Civilian Protection Act of 2019 (116th, Caesar Act)—the statute that imposed sweeping penalties on Syria’s construction, energy, and financial sectors in response to atrocities committed under Bashar al-Assad. Unlike most sanctions frameworks, the 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. 

Amendment 3662, introduced by Senator Jeanne Shaheen (D-New Hampshire), calls for full repeal of the Caesar Act and removal of all statutory sanctions authorities it established. 

Amendment 3899, sponsored by Senators Lindsey Graham (R-SC) and Chris Van Hollen (D-MD), takes a conditional approach. As modified on the Senate floor, it establishes a post-repeal certification framework requiring the Administration to report every 120 days on Syria’s conduct. Sanctions would automatically “snap back” if two consecutive certifications are not met.

Under the amendment, the president must certify to Congress every four months that the Syrian government meets the following criteria: 

• Is committed to eliminating ISIL and other terrorist threats and has joined the Global Coalition
• Provides security for religious and ethnic minorities, including them in government
• Maintains peaceful relations in the region, including with Israel, and is taking action against groups threatening regional security
• Is not knowingly financing, arming, or sheltering individuals or groups hostile to US national security or to US allies and partners in the region
• Has removed, or is in the process of removing, foreign fighters from the Government of Syria, including those in state and security institutions
• Is in the process of investigating and has committed to prosecuting individuals or entities that have committed serious abuses of internationally recognized human rights since 8 December 2024, including those responsible for the massacre of religious minorities. 

Failure to meet these benchmarks for two reporting periods would trigger automatic re-imposition of Caesar Act sanctions, with enforcement authority remaining under the president. 

CONTEXT AND ANALYSIS: Since 23 May 2025, the Secretary of State and Secretary of the Treasury have exercised six-month waivers under the Caesar Act, renewable upon biannual certification that each extension serves US national security interests. The short renewal cycle has fueled investor caution, discouraging long-term commitments in Syria due to the risk of abrupt policy reversals. Although several multinational companies are cautiously re-entering Syria or exploring opportunities, the Act continues to exert a chilling effect more through perception and risk tolerance than through direct legal barriers. The constant risk of “snap-back” continues to deter long-term investment, freezing capital, delaying recovery, and discouraging refugee return.²

Supporters of Amendment 3662 argue that maintaining the Caesar framework hinders humanitarian operations and reconstruction, while opponents warn that repeal would remove one of Washington’s few remaining tools of leverage over Damascus and weaken mechanisms for continued accountability. 

Amendment 3899 proposes a more cautious approach. It would require the President to report to Congress every 120 days on whether Syria meets the six specified conditions. If two consecutive certifications are missed, sanctions would automatically “snap back.” Proponents view this framework as balancing economic recovery and humanitarian relief with continued congressional oversight.

The Graham–Van Hollen amendment’s revised version 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.

Several of the amendment’s criteria are uncontroversial. Syria has already demonstrated compliance with most of them, including commitments to fight ISIL, protect minorities, and maintain regional stability. The government’s plan to resolve the As-Suwayda crisis and its ongoing cooperation with the Global Coalition and neighboring states address these conditions directly. The remaining provisions—particularly those concerning foreign fighters and relations with Israel—continue to generate debate in Washington and among international partners.

Condition 5, addressing foreign fighters, remains particularly sensitive for Damascus. The Trump Administration dropped this requirement months ago and has largely avoided the issue since. Many governments accept Syria’s view that keeping foreign fighters under state control is preferable to forcing their removal, while Graham’s effort to restore the clause could reignite a divisive debate. 

Condition 3, dealing with Israel, is also contentious. Israel continues to occupy Syrian territory seized in 1967, and has expanded its military operations inside Syria while supporting separatist groups. Critics argue that placing the burden solely on Damascus distorts the reality of the conflict and sets an unrealistic standard absent US pressure on Israel to withdraw. 

Looking ahead, 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 versions. With the House still out of session amid the government shutdown, the timeline remains uncertain, though the Caesar provisions are not expected to be a major source of disagreement. 

The Senate’s inclusion of Amendment 3662 and the subsequent attachment of the modified 3899 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. 

OFAC Rebrands Syria Sanctions Framework, Ends Territory-Wide Restrictions

The US Treasury Department’s Office of Foreign Assets Control (OFAC)—the body enforcing economic sanctions—has issued a final rule, effective 25 September 2025, amending the Syria-Related Sanctions Regulations. The rule changes the title to the Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations and implements Executive Orders (EO) 14142 and 14312. 

EO 14142, issued on 15 January 2025, removed all references to Türkiye from the Syria sanctions framework, specifically striking language related to Türkiye’s 2019 military offensive from Executive Order 13894.³ EO 14312, issued on 30 June 2025, revoked most sanctions on Syria itself while retaining measures targeting individuals and entities implicated in human-rights abuses, war crimes, and narcotics trafficking. 

CONTEXT AND ANALYSIS: OFAC’s updated framework integrates key statutes, including the Caesar Syria Civilian Protection Act, the Syria Human Rights Act, and the Illicit Captagon Trafficking Suppression Act, while refining OFAC’s Specially Designated Nationals (SDN) List identifiers. The original Syria-Related Sanctions Regulations were issued on 5 June 2020 to implement EO 13894, which addressed threats to US national security and foreign policy posed by the situation in Syria. 

The latest amendments under EO 14142 and EO 14312 represent a major policy shift—moving Syria out of the category of comprehensively sanctioned jurisdictions and narrowing restrictions to specific individuals and entities implicated in human-rights abuses, war crimes, and narcotics trafficking. 

In practical terms, Syria is no longer treated as a fully embargoed territory. Instead, sanctions now focus on maintaining pressure on actors linked to war crimes, human rights violations, and the regional narcotics trade. The shift indicates Washington’s intent to preserve leverage over Assad regime-affiliated elites while opening limited space for stabilization and reconstruction activity under international oversight.

Syria remains a high-risk investment environment, but due diligence programs can now shift focus from geographic legal exposure to SDN-level link analysis, particularly for networks tied to human rights abuses and captagon trafficking.

UN Security Council Reviews Draft Resolution to Ease Sanctions on Syria

The United Nations Security Council is reportedly reviewing a draft resolution that would ease long-standing sanctions on Syrian officials and re-establish international engagement with the Syrian government. The US reportedly circulated the draft among the Council’s 15 members on 9 October 2025.

The resolution would permit the transfer of financial assets, funds, and economic resources to Syria’s central government, effectively ending the asset freeze imposed under paragraph 1(a) of Resolution 2368 (2017). Under the draft, this measure would no longer apply to the provision of funds or other financial resources to the Syrian government, even if individuals or entities listed under the ISIL and al-Qaeda Sanctions List are involved in the government. 

If adopted, the resolution would also ease restrictions on arms transfers. While there is no formal UN arms embargo on Syria itself, the draft acknowledges that restrictions continue to apply to entities and individuals listed under the al-Qaeda and ISIL (Da’esh) Sanctions List. The arms embargo imposed under paragraph 1(c) of Resolution 2368 currently applies only to those groups and persons, but because key members of the Interim Government and Military were formerly part of HTS, which remains listed, these sanctions have implied a de facto arms embargo on the government. The resolution states that it would no longer apply to the supply of arms, related materials, or technical assistance to the Syrian government, provided that such support is delivered: 

• by member states acting in coordination with the Organisation for the Prohibition of Chemical Weapons (OPCW), to help identify, secure, and destroy chemical weapons and related materials, in line with the Chemical Weapons Convention and UN Security Council Resolution 2118 
• by member states working with the International Atomic Energy Agency (IAEA) on safeguards and related activities to reduce proliferation risks, consistent with the Treaty on the Non-Proliferation of Nuclear Weapons
• by member states supporting mine-action services aimed at mitigating explosive-ordnance risks and facilitating the safe return of displaced persons.

Finally, the draft calls for removing President Ahmad al-Sharaa and Interior Minister Anas Khattab from the UN sanctions list. Separately, around the time of these discussions, the Security Council updated the terrorism designation for Abu Muhammad al-Jawlani, changing it to his real name Ahmad al-Sharaa and updating his date of birth now that it is known publicly. 

CONTEXT AND ANALYSIS: In late July, the US mission to the UN argued that the Syrian Interim Government had demonstrated a clear commitment to combating al-Qaeda and ISIL and that the UN should lift sanctions imposed on current Syrian government figures and associated groups. The current list names Hay’at Tahrir al-Sham (HTS), Interim President Ahmad al-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). 

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 prevent their nationals from providing financial or material support. Importantly, there is no UN-wide arms embargo targeting Syria as a state. The only standing embargo applies to listed terrorist groups, such as HTS, and their members. However, because HTS now effectively controls parts of the Syrian government and military apparatus, these counterterrorism sanctions might imply a de facto arms embargo on Syria itself. The current resolution seeks to clarify and partly roll back this overlap by allowing arms and technical assistance under narrowly defined UN-supervised exceptions. 

China remains the main obstacle to delisting. Beijing remains concerned with the Syrian military’s integration of Uyghurs from the Turkistan Islamic Party (TIP), a transnational jihadist group seeking to establish an Islamic state in Xinjiang and Central Asia. Several TIP militants now hold senior positions in the Syrian Armed Forces, and the newly formed 84th Division is composed of Uyghurs and other foreign fighters. Despite these concerns, discussions with officials involved in the process suggest that China is more likely to abstain than to oppose the resolution. 

Russia shares similar concerns regarding 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 October visit to Moscow—the first since the fall of the Assad regime—signals a potential thaw in relations after his rebel forces toppled Bashar al-Assad in 2024. President Vladimir Putin has hinted at Russia’s willingness to reset ties with the new Syrian leadership.

Even if the UN delists Sharaa and Khattab, uncertainty remains over the status of HTS. The proposed easing of the arms embargo could, however, facilitate operations by UN nuclear, chemical-weapons, and mine-action agencies in Syria, improving safety and enabling progress toward reconstruction and stabilization.

UK Removes Terrorism Designation on Hay’at Tahrir al-Sham 

On 21 October 2025, the British government removed Hay’at Tahrir al-Sham (HTS) from its list of banned terrorist organizations. HTS, a former al-Qaeda affiliate, had been proscribed in 2017, making it illegal to join or support the group. The government stated that the delisting would enable closer engagement with Syria’s new government and facilitate cooperation on dismantling the Assad regime’s remaining chemical weapons program. It added that the UK would continue to pursue meaningful progress and hold the Syrian government accountable in its counterterrorism efforts and regional stabilization efforts. 

CONTEXT AND ANALYSIS: The decision to delist HTS follows the Trump administration’s July move to revoke HTS’s designation as a Foreign Terrorist Organisation (FTO). It reflects a broader UK strategy to re-engage diplomatically with Syria’s leadership after Bashar al-Assad’s departure in December 2024. The Home Office described the step as “pivotal for enhancing counterterrorism cooperation, migration management, and regional stability.”

For the financial sector, the change is expected to reduce uncertainty for banks considering engagement with Syrian businesses, particularly as several former HTS members now hold positions in the post-Assad administration. When HTS was listed, any transaction that could be construed as supporting or benefiting the group—or individuals associated with it—exposed banks to serious criminal liability under counterterrorism-financing laws. Delisting removes this legal ambiguity for entities or individuals now part of Syria’s new government who were previously linked to HTS. The UK decision could also ease compliance constraints for British financial institutions exploring early recovery or reconstruction activity in Syria. 

While the delisting may lower compliance uncertainty and open space for humanitarian and stabilization actors to operate more flexibly, it also raises questions about multilateral coordination. With UN counterterrorism sanctions and HTS’s Specially Designated Global Terrorist (SDGT) designation still in place, it remains to be seen whether the UK’s action will meaningfully curb overcompliance and spur renewed engagement with Syria. 

Mastercard Signs MoU with Syria’s Central Bank to Develop National Payments Ecosystem 

Mastercard has signed a memorandum of understanding (MoU) with the Central Bank of Syria (CBS) to collaborate on developing a national payments ecosystem in the country. The agreement aims to enhance the infrastructure of digital payment systems, facilitate knowledge exchange, and promote financial inclusion. The partnership will expand access to essential financial services for millions of Syrians and explore ways to integrate banks and financial institutions in line with global best practices. Mastercard and the CBS plan to provide on-site training and technical exchanges to build local expertise in digital payments and financial technology.

CONTEXT AND ANALYSIS: Mastercard is a global company that provides advanced digital payment solutions to facilitate secure and accessible financial transactions. It does not extend credit or underwrite card issuance; its value lies in managing the payment processing layer and charging fees tied to transaction volume and network use. The agreement marks Mastercard’s first engagement with Syria in 14 years. The company exited the country after Western sanctions targeted Bashar al-Assad’s government for repressing peaceful protests. 

The MoU is not a commercial deal but a framework for dialogue and technical exchange. It allows Mastercard and the CBS to discuss digital payment infrastructure, financial inclusion, and regulatory reform without committing to immediate operations. Even in this exploratory form, the re-emergence of a major international financial actor signals that elements of the private sector are taking renewed interest in Syria’s gradual reintegration under President Ahmad al-Sharaa. 

Beyond card issuance, Mastercard specializes in helping central banks and financial institutions modernize payment systems, build interoperable platforms, develop digital ID frameworks, and strengthen risk management tools aligned with global standards. In a cash-based economy with little trust in banks, even limited collaboration could help Syria rebuild institutional foundations to reconnect with global finance.

If implemented, such cooperation could have far-reaching consequences. A functioning digital-payments system would facilitate domestic transactions, encourage savings in the formal sector, and enable electronic transfers for salaries, remittances, and humanitarian aid—gradually reducing the informal cash networks that have thrived during years of sanctions and conflict. For international donors, it would also create safer, more transparent channels for disbursing assistance.

Yet challenges remain formidable. Syrian banks still lack strong compliance systems and effective oversight mechanisms—critical prerequisites for sustained engagement with global financial networks.

Apple, Samsung, Zoom, and Meta Lead Syria’s Digital Reopening after US Sanctions Easing

Apple has removed Syria from its list of prohibited destinations, leaving North Korea as the only country under a full embargo. In parallel, Syria’s Ministry of Communications and Information Technology has reinstated access to Apple products and the official App Store. Samsung Electronics Levant, the regional branch of Samsung Electronics, announced it is resuming operations in Syria after a 14-year hiatus. Similarly, Zoom Video Communications is now operating in Syria for the first time since its founding, ending years in which users relied on VPNs to access the platform. Meanwhile, Meta—the parent company of Facebook, Instagram, WhatsApp, Messenger, and Threads—has reactivated paid advertising in Syria after years of technical restrictions, and users are now beginning to see sponsored ads on these platforms. 

CONTEXT AND ANALYSIS: The gradual return of global technology companies to Syria follows the issuing of EO 14312, signed by US President Donald Trump on 30 June 2025. The order ended the comprehensive Syria sanctions program while keeping targeted measures against Bashar al-Assad, figures associated with the former regime, and other destabilizing actors. It also waived provisions of the Syria Accountability and Lebanese Restoration Act of 2003, lifting the longstanding ban on most US exports to Syria and opening the door for non-humanitarian trade. In addition, EO 14312 removed restrictions under 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.

On 2 September 2024, the US Department of Commerce’s Bureau of Industry and Security (BIS) operationalized EO 14312 by easing export licensing requirements for civilian goods. The new rule allows US-origin consumer goods, software, and technology classified as EAR99—typically items for civilian use—as well as consumer communication devices and “mass market” software (including source code), to be exported without a license. Most Apple products fall under these low-sensitivity categories,⁴ making them eligible for simplified export procedures.

However, Syria remains on the State Sponsors of Terrorism (SST) list. The designation continues to trigger restrictions on exports, financial transactions, and access to international credit. Beyond its legal implications, the SST label exerts a strong deterrent effect on foreign direct investment by sustaining reputational and compliance risks. Even under the relaxed export regime, many high-value or dual-use technologies will still require individual licenses, compelling companies to proceed cautiously, conduct enhanced due diligence, and maintain rigorous compliance programs.

The return of Apple, Samsung, and Meta represents the clearest sign yet of Washington’s policy shift under EO 14312. By selectively reopening consumer-facing sectors, these companies are testing the waters for limited economic normalization. Along with the SST designation, the Caesar Act remains the central constraint on any meaningful recovery or reinvestment. Although the Secretaries of State and Treasury granted a six-month waiver in May 2025, the temporary nature of the measure offers little assurance to investors wary of snapback sanctions or shifts in US domestic politics.

State Sponsor of Terrorism (SST) Review and Implications

The US State Department is expected to release its six-month review of Syria’s designation as a State Sponsor of Terrorism (SST) by 30 December. After the review, the State Department will decide whether to remove Syria from the SST list. The US first imposed this designation on 29 December 1979, marking the first time Washington had ever applied it. The decision cited Syria’s support for armed Palestinian factions and other non-state actors opposing Israel, which it classified as terrorism. 

CONTEXT AND ANALYSIS: On 30 June 2025, President Trump signed Executive Order 14312, “Providing for the Revocation of Syria Sanctions.” Under Section 8(b) of EO 14312, the Secretary of State will “take all appropriate action to review the designation of Syria as a State Sponsor of Terrorism.”

However, signs that Washington was reconsidering Syria’s SST status had emerged earlier. In May 2025, Thomas Barrack, US Ambassador to Türkiye and Special Envoy for Syria, said Washington no longer considered Syria an SST, noting that the issue was “gone with the Assad regime being finished.” His comments suggested that the internal review process was already underway before the Executive Order’s publication. Given the six-month review period he referenced, the SST label could be formally lifted before the end of 2025. 

Lifting the SST designation would mark a pivotal milestone in Syria’s diplomatic and economic rehabilitation. It would allow the US to resume certain forms of foreign assistance, permit access to international financial institutions, enable export financing under US government programs, and open channels for preferential trade benefits. It would also remove key barriers to bilateral trade and multilateral lending, particularly from the World Bank and the International Monetary Fund.⁵

Removal of the label would not immediately normalize US–Syria relations. Syria would remain subject to targeted sanctions related to human rights abuses, narcotics trafficking. Residual Caesar Act provisions, as well as the Syria Human Rights Act and Syria Accountability Act would also remain in force. Congress could still reimpose restrictions if the new government fails to maintain commitments on counterterrorism or minority protection.

For investors and humanitarian actors, delisting would reduce reputational and compliance risks, paving the way for the gradual reintegration of Syria into the global economy. Because the US typically reserves the label for states it considers global pariahs, the stigma attached to the listing can be stronger than that of other sanctions. 

Even when legal avenues exist, the uncertainty and stigma of ties to a US-designated SST are often too great for businesses. The case of Sudan illustrates this well: even after Washington lifted comprehensive economic sanctions in 2017 to encourage private-sector engagement, most firms stayed away. The SST designation remained in place until 2020, contributing to a chilling effect that outweighed formal easing measures. US officials reportedly had to send comfort letters to domestic banks, reassuring them that facilitating accounts for the Sudanese Embassy in Washington was permitted and supported by the US government. 

Hence, the transition will depend on follow-up regulatory guidance from the Departments of State, Treasury, and Commerce, and on parallel moves by European and regional partners to align their sanctions regimes.

1. The US federal law which specifies the budget, expenditures, and policies of the US Department of Defense.
2. What makes the snapback significant is that it would reinstate the Caesar Act in full, including its secondary sanctions, which impose penalties on non-US entities doing business with Syria.
3. EO 14142 removed references to Türkiye’s 2019 military offensive from the text of EO 13894.
4. EAR99, 5A992.c, or 5D992.c
5. For more details about the designation’s consequences: “Syria’s SST Designation: Implications and Pathways for Lifting.”