By Vittorio Maresca di Serracapriola and Natasha Hall
Issue 4: December 2025
At a Glance
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- US Repeals the Caesar Act, Opening Space for Investment – President Trump signed the FY2026 National Defense Authorization Act repealing the Caesar Act.
- US Tri-Seal Advisory Amended After Caesar Repeal – US agencies updated their Syria Tri-Seal Advisory and retagged Specially Designated Nationals entries away from “SYRIA-CAESAR” toward other authorities.
- UK Issues Investment Guidance on Syria – London published new guidance clarifying which Syria-related prohibitions still apply.
- Canada Removes Syria’s Terrorism Designation and Delists HTS – Ottawa removed Syria from its state-supporter-of-terrorism list and revoked HTS’s domestic terrorist designation.
- Visa Moves to Re-Enter Syria’s Payments Sector – Visa reached an initial roadmap agreement with the Central Bank of Syria to help rebuild the country’s digital-payments infrastructure.
- UK Imposes New Sanctions on Syrian Militias and Assad-Linked Financiers – The UK sanctioned Syrian National Army factions, their commanders, and Assad-linked financiers over alleged abuses and regime support.
- Sanctioned Assad-Era Commanders Are Reportedly Recruiting Fighters in Exile – New reporting suggests sanctioned ex-regime networks are rebuilding capacity from abroad through recruitment, money movement, and lobbying.
Contents
US Repeals the Caesar Act, Opening Space for Investment
On 18 December 2025, US President Donald Trump signed into law the National Defense Authorization Act (NDAA) for the Fiscal Year (FY) 2026, which includes the effective repeal of the Caesar Syria Civilian Protection Act of 2019 without snapback provisions. The NDAA was passed by the House of Representatives on 10 December and by the Senate on 15 December. While the repeal is unconditional, its continuation is not. Reflecting congressional concern over rapid normalization, the final text introduces a new oversight mechanism replacing the blanket sanctions. The legislation requires the US President to report to Congress within 90 days of enactment, and every 180 days thereafter for four years, certifying that the Government of Syria is meeting the following conditions:
- Taking concrete measures against ISIS and Al-Qaeda in partnership with the US
- Removing foreign fighters from senior positions in the government and security institutions
- Upholding religious and ethnic minority rights
- Not taking unilateral, unprovoked military action against its neighbors, including Israel
- Taking steps to implement the agreement of 10 March 2025 between the Government of Syria and the Syrian Democratic Forces
- Halting terror financing and the financing of proliferation of weapons of mass destruction, and not harboring individuals designated as terrorists who pose a threat to US national security
- Prosecuting perpetrators of gross human rights violations committed since 8 December 2024
- Taking verifiable steps to stop the production and trade of drugs, specifically captagon.
If these conditions are not met for two consecutive reporting periods, section 8369 of the NDAA provides that the President “may consider whether to impose targeted sanctions on individuals under existing authorities,” creating a statutory “snapback” capability distinct from the expired Caesar Act provisions.
CONTEXT AND ANALYSIS: The Caesar Syria Civilian Protection Act of 2019, which imposed mandatory secondary sanctions on third-party investors, remained the most significant legal hurdle to international investment. As long as the Caesar Act stayed in force, non-US companies—particularly from the Gulf and Europe—risked being cut off from the US financial system for engaging in “significant transactions” with Syria. Acknowledging the slow pace of the legislative process, the Secretary of State issued a renewable 180-day waiver of Caesar Act sanctions on 23 May 2025, alongside General License 25 (GL25), which authorized transactions otherwise prohibited under the Syrian Sanctions Regulations. The administration renewed the waiver again in November 2025, suspending the threat of secondary sanctions as Congress worked toward permanent repeal.
During the second half of 2025, repealing the Caesar Act became central to negotiations over the NDAA for FY2026. On 9 October 2025, the US Senate passed S. 2296, its version of the NDAA, which included Amendment 3662. Senator Jeanne Shaheen (D-NH) had introduced the amendment, explicitly repealing the Caesar Act. On 8 December 2025, the House and Senate Armed Services Committees released the final negotiated text of the FY2026 NDAA, which retained the repeal provisions.
Repealing the Caesar Act removes a major source of legal uncertainty that has blocked reconstruction and long-term investment. Eliminating mandatory sanctions and snapback provisions is critical, as it removes the risk of automatic sanctions reimposition following political or security setbacks. Short-term waivers never provided private investors or regional governments with the confidence needed to commit substantial capital.
Despite the repeal, sanctions relief remains incomplete. Syria remains designated as a State Sponsor of Terrorism (SST). As a result, significant export controls continue to apply. The US still subjects Syria to strict controls under Export Administration Regulations (EAR), due to its placement in Country Group E:1. This classification requires licenses even for low-risk items, such as hospital IT equipment or laboratory machines, and extends US jurisdiction to goods containing minimal US content.
If the US follows the regulatory precedent set after Sudan’s removal from the SST list, the Bureau of Industry and Security (BIS) would remove Syria from EAR Country Group E:1 and raise the de minimis threshold for US export control jurisdiction from 10 percent to 25 percent. These changes would reduce the number of items subject to US export controls, expand Syria’s eligibility for license exceptions under the EAR, and eliminate the most stringent anti-terrorism-related restrictions. Once implemented, these measures would ease access to parts and machinery needed for reconstruction and development, while lowering barriers to consumer imports and routine business operations. However, none of these changes would take effect until the US removes Syria from the SST list and BIS publishes a formal rule amending the EAR.
Finally, Hay’at Tahrir al-Sham (HTS) remains designated under the UN 1267 ISIL and Al-Qaeda sanctions regime, and the US continues to list HTS as a Specially Designated Global Terrorist (SDGT). This lingering designation carries potential sector-wide implications, as current Syrian institutions remain close to the group. Approximately one-third of serving ministers have historical ties to HTS, raising continued compliance and risk-assessment challenges for external actors.
US Tri-Seal Advisory Amended After Caesar Repeal
The US Department of State, the US Department of Commerce, and the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) have issued an amended Tri-Seal Advisory, “Sanctions and Export Controls Relief for Syria,” reflecting the repeal of the Caesar Syria Civilian Protection Act of 2019. OFAC has also updated the Specially Designated Nationals and Blocked Persons List (SDN List) to reflect the repeal. In total, 16 SDN entries were updated, with seven individuals and nine entities being re-anchored under OFAC’s “Promoting Accountability for Assad and Regional Stabilization Sanctions” (PAARSS) program.
CONTEXT AND ANALYSIS: On 10 November, the three government departments issued a Tri-Seal Advisory titled “Sanctions and Export Controls Relief for Syria.” Tri-Seal Advisories clarify the US sanctions posture toward a specific jurisdiction or sector, guide banks, companies, and foreign governments through rapidly changing rules, signal political intent, and reduce overcompliance.
Following Congress’s repeal of the Caesar Act, the amended Tri-Seal Advisory and OFAC’s SDN updates make clear that the shift is mainly legal and administrative, not a blanket retreat from targeted pressure. OFAC is retagging SDN entries that previously carried a “SYRIA-CAESAR” identifier alongside Syria accountability authorities so that they now reflect only the PAARSS/EO 13894 basis. This is best understood as consolidation: the blocking consequences for still-designated actors remain, but the statutory hook is removed and the operative authority is made explicit.
With broader Syria measures rolled back, PAARSS has now become the durable container through which the US maintains conduct-based, targeted pressure on regime-linked networks and other specified harmful conduct, while pairing that pressure with licensing and clearer compliance pathways. Whether this more streamlined architecture—featuring fewer overlapping labels and cleaner authority mapping—will meaningfully reduce transaction costs for licensing, humanitarian operations, and other permitted activity remains to be seen.
UK Issues Investment Guidance on Syria
On 2 December 2025, the United Kingdom (UK) published investment guidance for companies, banks, and NGOs considering investment in Syria, titled Supporting a Secure and Prosperous Future for Syria: Guidance for Businesses and NGOs. The guidance clarifies which prohibitions remain in force. These include asset freezes on designated individuals and entities; trade restrictions on the export, supply, or transfer of chemical and biological weapons-related goods and technology; internal repression goods; and interception and monitoring technologies. Additional measures prohibit the provision of gold, precious metals, or diamonds—and related technical assistance—to Syria’s transitional authorities, including the Central Bank. The UK also maintains bans on luxury exports to Syria and on imports of military, security, and paramilitary goods, as well as arms, ammunition, and related materiel. The guidance further clarifies that while HTS remains designated under the UN 1267 sanctions regime, the Syrian government and its ministries are not designated under any UK sanctions regime.
CONTEXT AND ANALYSIS: In April 2025, the UK lifted sanctions on several Syrian government entities, following the removal of restrictions on most banks and oil companies in March 2025. At the same time, it kept sanctions in place on members of the Assad regime.
In November 2025, the Department for Business and Trade (DBT) issued separate guidance for UK companies interested in Syria, describing it as a “potentially high-return market” despite its challenging and high-risk environment. That guidance highlighted several potential advantages for UK exporters: a new government seeking to attract foreign private investment and accelerate public-sector reform; demand for British goods and services; and the return of Syrians after more than a decade of war, which could support economic recovery and output. Notably, the document did not list sanctions among the core commercial challenges, although a later legal section reminded firms of compliance obligations. The December guidance notes that UK businesses have recently shown growing interest in exploring opportunities in Syria. Firms have also pressed the government for greater clarity on the legal and policy frameworks governing investment and commercial engagement.
According to UK companies interviewed by Karam Shaar Advisory, the Department for Business and Trade (DBT) presents the UK as “open for business” in Syria, but its responses suggest that it is not yet prepared to support meaningful commercial engagement. Officials tend to default to generic, copy-pasted public links that fail to address concrete questions about opportunities or operational constraints. The reported issue is that the DBT cannot provide guidance even on relatively straightforward professional services, raising doubts about its ability to support more complex goods-based exports or service provision.
Canada Removes Syria Terrorism Designation And Delists HTS
Canada has removed Syria from its list of states that support terrorism, citing a similar move by the US and the Syrian government’s efforts to stabilize the country under President Ahmad al-Sharaa. Canada’s foreign ministry also revoked HTS’ terrorist designation under the Criminal Code. The Canadian Foreign and Public Safety Ministries said the measures align with recent decisions by Canada’s allies, including the UK and the US.
CONTEXT AND ANALYSIS: Canada designated Syria a state supporter of terrorism in 2012, as Bashar al-Assad’s violent repression of pro-democracy protests pushed the country into civil war. In March 2025, Ottawa announced plans to ease sanctions and committed CAD 84 million (approximately USD 61.4 million) in new humanitarian assistance for Syria. Canada also issued a six-month general permit allowing Canadians to carry out otherwise prohibited financial transactions and services in support of democratization, stabilization, and humanitarian aid delivery.
The decision to delist HTS mirrors a similar move by the UK. It remains unclear, however, whether the measure fully complies with the UN 1267 sanctions regime, which continues to designate HTS, and the UN Charter’s national implementation requirements. The US, for instance, still lists HTS as a Specially Designated Global Terrorist (SDGT).
Canada’s move reduces legal and reputational risk for engagement with Syria under Canadian law, particularly in banking and logistics. By removing the terrorism designation, Canada lowers barriers to correspondent banking, trade finance, insurance, and shipping. Canadian-linked firms may begin testing early re-entry into Syria-related transactions, particularly in reconstruction-linked goods, energy services, and critical imports.
Meanwhile, companies and NGOs now operate in an increasingly fragmented sanctions environment. Activities permitted under Canadian rules may still trigger legal or reputational exposure under US regimes, especially given Syria’s remaining State Sponsor of Terrorism designation and HTS’s continued SDGT listing.
Visa Moves to Re-Enter Syria’s Payments Sector
Payments company Visa is set to restart operations in Syria after reaching an agreement with the country’s Central Bank on a roadmap to develop a digital payments ecosystem. Visa said it will initially focus on working with licensed financial institutions to build a secure payments foundation. This effort will include issuing payment cards and enabling digital wallets using global standards, including Europay, Mastercard, and Visa (EMV) chips and tokenization. For local businesses, Visa will support acceptance through the Visa Acceptance Platform, which allows the deployment of low-cost, open acceptance solutions such as Tap to Phone and QR codes.
CONTEXT AND ANALYSIS: The agreement marks Visa’s first engagement with Syria in 14 years. The company exited after Western sanctions targeted Bashar al-Assad’s government for violently repressing peaceful protests. The new arrangement does not constitute a commercial deal but rather establishes a framework for dialogue and technical exchange. Even in this exploratory form, the re-emergence of a major international financial actor signals renewed private-sector interest in Syria’s gradual reintegration under President Ahmad al-Sharaa. Mastercard took a similar step in October, signing a memorandum of understanding with the Central Bank of Syria to collaborate on developing a national payments ecosystem. That agreement focused on upgrading digital payments infrastructure, facilitating knowledge exchange, and promoting financial inclusion.
If implemented, such partnerships could have far-reaching effects by facilitating domestic transactions, encouraging savings within the formal sector, and enabling electronic transfers for salaries, remittances, and humanitarian aid. Over time, it could reduce reliance on informal cash networks that expanded during years of sanctions and conflict. For local businesses, low-cost acceptance tools such as Tap to Phone and QR codes could help small and medium enterprises integrate into formal payment networks with minimal upfront investment. Yet challenges remain formidable. Syrian banks continue to lack robust compliance systems and effective oversight mechanisms, both critical prerequisites for sustained engagement with global financial networks.
UK Imposes New Sanctions on Syrian Militias and Assad-Linked Financiers
The UK has announced new sanctions against three militia groups and four militia commanders accused of involvement in suspected atrocities during clashes in Syria’s coastal regions in early 2025, which left more than a thousand people dead. The UK will also sanction two businessmen for providing financial support to the regime of former president Bashar al-Assad.
The sanctioned militia commanders are Ghaith Dalla and Miqdad Fatiha, both former senior regime military commanders who lead pro-regime militia groups, as well as Mohamad al-Jasim, commander of the Sultan Suleiman Shah militia group, and Sayf Boulad, commander of the Hamza Division militia group. The sanctioned businessmen are Mudallal Khoury and Imad Khoury, Syrian-Russian nationals who helped finance Assad regime activities.
All designated individuals are subject to an asset freeze, a travel ban, and a prohibition on acting as company directors in the UK. The UK has also imposed asset freezes on three armed groups: the Sultan Murad Division, the Sultan Suleiman Shah Division, and the Hamza Division.
CONTEXT AND ANALYSIS: On 27 May 2025, the European Union (EU) sanctioned three Syrian militia groups and two of their leaders over human rights abuses committed against members of Syria’s Alawite minority during a wave of deadly ethnic violence in March 2025. The decision came just one week after the bloc agreed to lift broader sanctions on Syria. The violence, concentrated along Syria’s coast, primarily targeted the Alawite community.
The UK’s latest designations follow a similar logic, even as London moves to ease certain economic sanctions to support post-war reconstruction after Assad’s downfall in 2024. By sanctioning not only figures tied to the former regime but also commanders and armed factions now incorporated into Syria’s transitional security forces—and by explicitly citing their role in the March coastal violence—the UK signaled that integration into the new state does not confer immunity for past abuses. These designations carry particular weight because the sanctioned commanders now occupy positions within the reconstituted military structure.
Sanctioned Assad-Era Commanders Are Reportedly Recruiting Fighters in Exile
Recent reporting suggests former Assad-regime figures and allied networks are organizing insurgent plots from outside Syria, prompting concern that a post-regime armed challenge could emerge in exile. Transcribed calls and messages indicate senior former commanders, including Suhail Hassan and former intelligence chief Kamal Hassan, have discussed recruiting fighters, moving funds, and in some cases procuring weapons. The reporting also cites Ghiath Dalla, the former Fourth Division commander now in Lebanon, as saying an insurgency would not begin until the network is fully armed. Reports further say the network brought Muhammad al-Hasouri into the effort this year; Hasouri is a former air force commander accused of involvement in the 2017 Khan Sheikhoun chemical attack.
Separately, coverage says Rami Makhlouf, Assad’s cousin and a longtime regime-linked business tycoon, alongside Kamal Hassan is financing large numbers of fighters and moving money through intermediaries in Lebanon, the UAE, and Russia to pay salaries and purchase equipment. One figure has also reportedly backed a million-dollar lobbying campaign in Washington through the Foundation for the Development of Western Syria, fueling fears that such efforts could gradually build support for a semiautonomous region in Syria.
CONTEXT AND ANALYSIS: Both Suhail Hassan and Kamal Hassan are already designated under international sanctions frameworks tied to alleged abuses, yet the reporting suggests these measures have done little to curb their ability to operate. After relocating to Moscow with Bashar al-Assad in December 2024, they reportedly continued to move through regional corridors, particularly Lebanon, using personal networks to maintain contact, vet intermediaries, and, in Kamal’s case, disburse payments to supporters and potential recruits.
The earliest intercepted communications cited in the reporting date to April 2025, shortly after a sharp spike in sectarian violence along Syria’s coast that reportedly left more than 1,500 people dead, mostly Alawites, following clashes triggered by attacks on the new government’s forces. That episode appears to have hardened communal fear and grievance, creating a permissive environment in which ex-regime figures could frame themselves as protectors. Subsequent Alawite protests—first in late November, then again in Latakia on December 28 when demonstrations devolved into deadly violence—illustrate the depth of mistrust toward Damascus and the contested nature of leadership within the community.
From a sanctions policy perspective, the reporting highlights identifiable pressure points: the jurisdictions where key figures reportedly operate and the facilitators—logistics providers, travel enablers, cash movers, and front entities—required to sustain their activities. Authorities and regulated entities can test these hypotheses through transaction records, compliance data, and cross-border cooperation requests. A recent mapping effort by the Observatory of Political and Economic Networks traced the whereabouts of 131 designated individuals and found the largest clusters in Russia, the UAE, and Lebanon.
The UAE dimension is particularly actionable because it intersects with identifiable asset classes and regulated service providers. In 2024, Syrians reportedly owned 3,716 Dubai properties worth USD 1.8 billion in total, including holdings linked to at least ten sanctioned individuals. Such concentrations provide concrete leads for asset tracing, beneficial-ownership analysis, and pressure on gatekeepers.
If the reporting is accurate, the central weakness is not the sanctions architecture itself but the gap between designation and implementation. While uneven enforcement has long been a feature of sanctions regimes, Russia’s role now matters more because the network’s operational hub appears consolidated in a jurisdiction hostile to Western enforcement and already heavily sanctioned. With limited scope for pressure at the center, EU, US, and UK policy is pushed toward what remains influenceable: the cross-border connective tissue—third-country intermediaries, travel corridors, payment rails, procurement pathways, and reputational vehicles—that links a Russia-based hub to regional networks and to advocacy channels in the West.