By Vittorio Maresca di Serracapriola and Natasha Hall
Issue 5: January 2026
At a Glance
- Graham Warns of US Sanctions over Raqqa Fighting – Senator Lindsey Graham said continued clashes with the SDF could trigger renewed sanctions.
- Syria Relaunches Currency with Russian-Printed Banknotes – Damascus began redenominating the Syrian pound using notes reportedly printed by Russia’s sanctioned firm Goznak, raising compliance risks.
- US Congress Moves to Update Captagon Sanctions Framework – A bipartisan bill seeks to adapt the US sanctions framework to the post-Assad narcotics trade.
- Mohamad Hamsho Settles with Transitional Authorities – Syria’s Illicit Gain Combating Committee reached a settlement with the sanctioned Assad-linked tycoon, recovering hundreds of millions of dollars.
- EU Court Rejects Delisting Request by Feras al-Akhras — The Court of Justice rejected a delisting bid by Asma al-Assad’s brother, reinforcing tougher judicial standards for Assad-network challenges.
- Mastercard Grants QNB Syria License — Mastercard granted QNB Group a license to resume card-issuing and acquiring operations in Syria.
- Estithmar Holding Enters Syria’s Banking Sector — Estithmar, a Qatari group, is set to take control of Shahba Bank and acquire a 30 percent stake in Syrian International Islamic Bank.
Contents
Graham Warns of Renewed US Sanctions as Syrian Forces Advance Toward Raqqa
US Senators Lindsey Graham (R-SC) and Richard Blumenthal (D-CT) introduced the Save the Kurds Act in response to repeated attacks by Syrian government forces on the Kurdish-led Syrian Democratic Forces (SDF). On 19 January 2026, Graham warned that Washington could reimpose and expand sanctions on Syria if interim government forces continue advancing north toward Raqqa. In a social media post, he said he would push to reactivate Caesar Act sanctions “on steroids” if operations persist, arguing that Syrian authorities have ignored repeated US warnings.
The Save the Kurds Act would:
- Impose sanctions on Syrian government officials and financial institutions, and on any foreign person providing military or financial support to the Syrian government
- Recognize the SDF for its role in US-led efforts to defeat ISIS
- Redesignate Hay’at Tahrir al-Sham (HTS) as a Foreign Terrorist Organization
- Require congressional review before Syria’s designation as a State Sponsor of Terrorism could be removed
- Authorize the president to suspend sanctions upon certifying that Syrian forces have ceased all attacks on the SDF and its partners
- Establish a snapback mechanism requiring immediate reimposition of sanctions if attacks on the SDF resume.
CONTEXT AND ANALYSIS: On 18 January 2026, President Ahmad al-Sharaa and SDF leader Mazloum Abdi signed a US-mediated ceasefire framework for integrating SDF institutions into the Syrian state. The agreement followed a year of largely stalled intense negotiations over governance and security arrangements in SDF-controlled areas. After talks broke down in early January, the interim government launched a rapid offensive into Kurdish-held territory, reaching Raqqa and Kobani within days.
The US administration also signaled growing frustration with the SDF’s political position. US Special Envoy Thomas J. Barrack Jr., writing on X on 20 January, said the SDF’s role as the primary anti-ISIS force “has largely expired,” arguing that Damascus can now assume security responsibilities. Transitional government forces then expanded their control, particularly in Arab-majority areas where SDF units withdrew. Many Syrians welcomed the shift, while many Kurds reacted with fear, particularly given reports of atrocities committed by government forces in coastal and southern regions in 2025, as Syrian government forces approached Kurdish areas such as Kobani and Hasakah. These areas host ISIS detention facilities guarded by the SDF and around 1,000 US troops, and in the ensuing chaos detainees escaped from SDF-run facilities.
These developments prompted congressional concern over the pace of US normalization with Damascus. Senator Graham wrote a series of statements on X threatening renewed sanctions, and he and Senator Blumenthal subsequently introduced the Save the Kurds Act on 29 January, citing the SDF’s role in defeating ISIS and warning that continued attacks on Kurdish forces risk regional instability, threaten US personnel, and enable an ISIS resurgence.
At the same time, US-brokered de-escalation continued. The SDF ceasefire was extended by 15 days in late January, even as the interim government consolidated control across former SDF-held areas. President Trump also signaled support for Damascus after speaking with President al-Sharaa on 28 January, saying he was “very happy” with developments in Syria, underscoring that the administration’s approach differs from congressional pressure and that the two sides are at odds.
While a full revival of Caesar Act sanctions remains unlikely, the FY 2026 NDAA introduces a new oversight regime. It requires the president to certify every 180 days that Syria meets eight conditions, including protection of minority rights and implementation of the 10 March 2025 agreement with the SDF. Failure to meet these benchmarks could trigger new targeted sanctions.
Syria’s Currency Relaunch Risks Re-Importing Sanctions via Russia
On 1 January 2026, Syria began swapping old banknotes for new ones as part of a redenomination designed to retire Assad-era notes and stabilize the currency. The authorities removed two zeros from the Syrian pound, introducing new bills denominated from 10 to 500 pounds. The notes entered circulation the same day and feature roses, wheat, olives, oranges, and other agricultural imagery associated with Syria.
CONTEXT AND ANALYSIS: In August 2025, Reuters reported that Syria planned to issue new banknotes and remove two zeros from the currency to restore confidence in the severely devalued pound. Syria had reportedly reached an agreement with Russia’s state-owned printing firm Goznak to produce the new notes during a delegation visit to Moscow in late July. There is no clear indication that Damascus received a green light from Washington for the move. Rather, the decision appears to reflect the ad hoc and constraint-driven nature of Syria’s economic governance, where operational choices are shaped less by strategic signaling than by immediate feasibility. Since July, the Central Bank Governor has repeatedly refused to say publicly where the currency is printed, calling it a sovereign matter. Goznak, a Russian state-owned firm under the Ministry of Finance, produces currency and security documents and has previously printed Libyan banknotes.
The US sanctioned Goznak in 2024 for supporting Russia’s Federal Security Service, accusing it of producing sensitive materials with military applications. The EU also sanctions Goznak for “printing all Russian passports, including passports distributed in the occupied regions of Ukraine…as well as military documents for Russia’s Defence Sector…which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine.”
Karam Shaar Advisory Ltd. tracked 18 flights from Moscow to Damascus by the Kyrgyzstan-based Moalem airlines (Flight No. 2Y4961) since last August, including 14 in December 2025 alone, one month before the rollout. A reliable source in the aviation sector said that this airline was previously used to transport currency under the Assad regime.
By resorting to a sanctioned company, the Syrian Central Bank exposes itself to US Russia-related sanctions risks under Executive Order (EO) 14024. OFAC treats all EO 14024-blocked persons (including Goznak) as part of Russia’s “military-industrial base.” Dealings that amount to a “significant transaction” can create secondary-sanctions exposure. If Damascus tasks Goznak with printing banknotes, it would anchor the country’s monetary operations to a heavily sanctioned Russian enterprise and import that sanctions exposure directly into prices and the banking sector—meaning higher transaction costs, reduced willingness by foreign banks to handle Syrian currency, and greater reliance on informal or cash-based channels due to secondary-sanctions risk. Syria already imported currency from Russia’s Goznak in February 2025, but this occurred before most EU, US, and UK sanctions were lifted, including EU prohibitions on printing currency for Syria.
With most Syria-specific sanctions lifted, reconnecting Syrian banks to the global financial system now depends on foreign financial institutions’ risk assessments. Correspondent banks will ask whether supporting a Syrian bank could mean facilitating a transaction for an EO 14024-designated entity. Since Goznak appears on the US SDN list and carries explicit secondary sanctions risk, it remains unclear whether US, EU, or UK banks will accept transactions involving the new currency.
New House Bill Seeks to Adapt the US Sanctions Framework for a Post-Assad Captagon Trade
On 22 January 2026, Rep. French Hill (R-AR) and Rep. Jared Moskowitz (D-FL) introduced the Countering Captagon and Narcotics Post-Assad Act (short title for HR 7180). The bipartisan bill updates Hill’s earlier Captagon Act to reflect shifts in narcotics production and to develop a US strategy for disrupting trafficking in captagon, methamphetamine, and other amphetamine-type stimulants.
CONTEXT AND ANALYSIS: The regime of former Syrian president Bashar al-Assad sponsored the country’s captagon trade. Media investigations linked state institutions, including the 4th Armored Division and Military Intelligence, as well as members of the Assad family, to the production and trafficking of the synthetic amphetamine-type stimulant, prompting international sanctions. Former HTS leader Ahmad al-Sharaa, now Syria’s interim president, has pledged to dismantle the trade and has backed this commitment with large-scale raids on captagon laboratories and stockpiles. Since the regime’s fall, authorities have carried out major seizures and arrested producers and smugglers, but the technical capacity to manufacture captagon remains and could migrate elsewhere.
Smuggling networks continue to operate, though at a reduced scale as regime-linked stockpiles decline. Southern Syria, particularly As-Suwayda, remains a key trafficking hub protected by local armed groups, while some production appears to be relocating to Lebanon. Regional responses have also evolved: Jordan has relied on airstrikes and intelligence coordination, while operations along the Lebanese border have intercepted precursor chemicals and counterfeit packaging. Despite early gains, the interim government lacks the capacity to sustain a regional counternarcotics campaign.
Against this fragile enforcement landscape, Congress is moving to update its captagon policy framework. HR 7180 builds on the 2022 CAPTAGON Act rather than creating a new sanctions regime. It amends the FY2023 NDAA’s captagon-related reporting requirements to reflect the post-Assad environment. Two shifts are central. First, the geographic focus expands from Assad-linked networks inside Syria to trafficking networks operating across the Middle East, while still explicitly covering actors tied to the former regime, Hezbollah, and Iran-backed proxies. Second, the bill moves beyond a captagon-only framework to cover amphetamine-type stimulants more broadly, elevating methamphetamine as a parallel threat.
Although the bill does not create new sanctions authorities, it keeps narcotics trafficking at the center of US Syria policy narrative and frames captagon and meth as enduring regional security threats that justify sustained pressure on Hezbollah- and Iran-linked networks. By mandating an interagency, unclassified strategy and structured assessments of transit states, capacity gaps, and cooperation frameworks, HR 7180 is likely to build the evidentiary basis for future targeted designations. As designations expand, compliance risk will widen beyond listed actors, discouraging legitimate trade and investment linked to Syria and raising transaction costs for firms operating in neighboring transit states.
Sanctioned Syrian Tycoon Hamsho Settles with Transitional Authorities
On 7 January, Syria’s Illicit Gain Combating Committee (IGCC) announced that it had reached a formal settlement with the internationally sanctioned Syrian businessman Mohamad Hamsho under its “voluntary disclosure programme,” a framework designed to recover illicitly acquired wealth. Long linked to the Assad regime’s inner circle, Hamsho reportedly settled with the transitional government through an agreement that included the recovery of hundreds of millions of dollars in cash and assets.
CONTEXT AND ANALYSIS: The voluntary disclosure program frames itself as a tool of “economic justice” and asset transparency aimed at businessmen who accumulated wealth through proximity to the former regime. Authorities allow those who can demonstrate lawful acquisition to retain control, while requiring the surrender of assets deemed illegitimate. The IGCC has not publicly disclosed either the total value of assets recovered or the mechanisms used to implement settlements. An IGCC source quoted by Enab Baladi, however, said the committee recovered roughly USD 800 million in cash and assets from Mohammed Hamsho. The committee also says it is investigating more than 900 businessmen and is finalizing settlements with Samer Foz and Wassim Qattan.
The EU listed Hamsho in May 2011, citing his association with Maher al-Assad, financial support to the regime, and involvement in the violent repression of civilians. The US later listed Hamsho and his holding company in August 2011. While negotiated settlements allow the transitional authorities to recover assets quickly, they also risk weakening future legal and sanctions enforcement. A domestic settlement can function as de facto rehabilitation inside Syria even as the same individuals retain the resources and networks that underpin their international risk profile.
Hamsho’s case also illustrates how political and commercial ties can shape accountability. He is accused of involvement in the violent repression of civilians along with close associate Maher al-Assad and is reportedly the uncle of Moutaz al-Khayyat, the Qatari-Syrian chairman of UCC Holding. UCC has recently secured major contracts in Syria, including contracts to build power plants and redevelop Damascus International Airport. Hamsho’s rehabilitation was reportedly through Qatari mediation via relatives, with Qatari officials reportedly contacting Damascus to negotiate a settlement in exchange for a financial payment.
For sanctions and compliance, domestic settlements cannot resolve external restrictions. Even where Syrian authorities treat an agreement as “clearance,” international counterparties must continue to treat a sanctioned individual or entity as high-risk until formal delisting and ownership clarifications occur. That gap between local legitimacy and international restrictions is where sanctions breaches, overcompliance, and procurement contamination typically arise, allowing politically connected actors to retain economic influence while accountability remains uneven.
EU Court Rejects Delisting Request by Asma al-Assad’s Brother
On 14 January 2026, the Court of Justice of the European Union rejected Feras al-Akhras’s request to be delisted from the EU’s Syria sanctions regime. Akhras is a Syrian businessman and the brother of Asma al-Assad, the wife of former Syrian president Bashar al-Assad. The EU sanctioned him because of that family connection and because he previously co-owned Takamol LLC, the company that managed Syria’s electronic “smart card” program. Since 2014, the Ministry of Domestic Trade and Consumer Protection has used this system to distribute subsidized food and other essential goods. Takamol earns a fee on every transaction processed through the card system. The EU Council therefore considered al-Akhras to be benefiting from and supporting the Syrian regime.
CONTEXT AND ANALYSIS: The judgment should be read against the backdrop of a broader wave of litigation by members of the Assad–Makhlouf family networks following the delisting of Hala Almaghout. Hala Almaghout is the widow of Mohamad al-Makhlouf, brother-in-law of Hafez al-Assad and father of Rami Makhlouf. Rami Makhlouf is a sanctioned billionaire Syrian businessman who is reportedly organizing an insurrection against the Syrian transitional government.
Since the annulled listing of Hala Almaghout, other family members have sought to challenge both the factual basis of their own listings and the legality of targeting family members. The Akhras ruling clarifies that while family ties alone do not suffice, proximity to the regime matters insofar as it generates a concrete risk of circumvention, including the transfer or channeling of frozen funds — a risk the Court now treats as an autonomous basis for maintaining sanctions.
The contrast with the Almaghout case remains instructive: her delisting rested on extensive evidence that she had no influence, had been persecuted by the former regime’s networks, and could not realistically be used as a financial intermediary, even though she has since been relisted under a subsequent legal act.
Mastercard Grants QNB License to Resume Activities in Syria
Mastercard announced on 5 January 2026 that QNB Group, a Qatari financial institution and the largest bank in the Middle East and Africa, has received a Mastercard license to extend its issuing and acquiring activities in Syria. The license allows QNB to offer Mastercard payment solutions to individuals and businesses.
CONTEXT AND ANALYSIS: In September 2025, Mastercard signed a memorandum of understanding with the Central Bank of Syria. The agreement focuses on upgrading digital payments infrastructure, facilitating knowledge transfer, and promoting financial inclusion. This engagement follows the post–July 2025 rollback of comprehensive US sanctions on Syria, which reopened legal space for US-linked payment networks and cross-border financial services, provided transactions do not involve individuals or entities still subject to targeted sanctions.
QNB is the first bank in Syria to secure a Mastercard license for “issuing and acquiring,” allowing it to provide cards to users and enable merchants to accept Mastercard payments. Mastercard said QNB’s payment solutions, accepted in Syria and internationally, will now become available to individual customers and businesses. This could allow Syrians to use electronic payment cards domestically and, potentially, for international payments, once acquiring networks, point-of-sale terminals, connectivity, electricity, and back-end processing capacity are restored. Point-of-sale terminals remain scarce after years in which international transactions were effectively shut down and cash dominated daily commerce.
Visa has also indicated plans to launch operations in Syria, suggesting a phased reintegration of payments infrastructure rather than a one-off arrangement. Such arrangements are often cited by payment networks as tools for reducing cash usage and improving transaction traceability, though implementation in Syria remains constrained by infrastructure and compliance limits. Visa has not yet granted a license to any bank operating in Syria for issuing and acquiring activities.
Yet challenges remain formidable. Remaining targeted listings mean banks and payment providers will still need robust sanctions screening and transaction controls. Any perceived exposure to designated actors could trigger abrupt de-risking by partners. Syrian banks still lack strong compliance systems and effective oversight mechanisms, which are critical prerequisites for durable engagement with global financial networks. Having been cut off for more than a decade, many institutions were never forced to modernize systems or align anti-money laundering and counterterrorism-financing frameworks with international standards. Syria’s ongoing FATF gray listing is likely to reinforce elevated risk perceptions, making onboarding and correspondent relationships difficult even where legally permitted. IT systems and staff training are also outdated. All this means that the rollout will depend as much on operational rebuild and governance upgrades as on formal licensing announcements.
Qatari Group Estithmar Holding Moves Into Syria’s Banking Sector With Two Bank Deals
Qatari group Estithmar Holding is set to take control of Syria’s Shahba Bank and acquire a 30 percent stake in Syrian International Islamic Bank (SIIB), marking the first foreign banking acquisitions in Syria since the fall of Bashar al-Assad. Estithmar, part of the Doha-based Power International Holding conglomerate led by the Syrian-Qatari brothers Moutaz and Ramez al-Khayat, will take a controlling 60 percent stake in Shahba after buying out shares of Banque Bemo Saudi Fransi and Ahli Trust Bank. The acquisitions are still subject to regulatory approval.
CONTEXT AND ANALYSIS: In 2012, the US and EU sanctioned SIIB for acting on behalf of the Commercial Bank of Syria and for providing services to the Syrian Lebanese Commercial Bank, both of which were under international sanctions. In 2014, the General Court of the EU delisted SIIB after the EU Council failed to provide sufficient evidence to justify maintaining the designation. The US followed suit in June 2025 after President Trump lifted sanctions on Syria.
The deal sends a positive signal. It points to renewed Gulf interest in Syria’s banking sector and suggests that regional investors are willing to place bets on Syria’s banking system at a time when many non-regional actors remain cautious. The transaction matters both as a confidence indicator and as a test case for whether foreign capital and governance capacity can begin to re-enter the sector.
These acquisitions would expand the Khayat brothers’ growing portfolio in Syria. Their companies already hold contracts for power generation projects and for the redevelopment and expansion of Damascus International Airport. The two billionaire brothers have also faced lawsuits in a British court alleging that they financed or assisted Al-Nusrah Front (an earlier iteration of Hay’at Tahrir al-Sham), including through accounts held at Doha Bank. The case, however, did not lead to a ruling on these allegations and was stalled by jurisdictional and procedural challenges.
For Estithmar, the strategic value also lies in its wider footprint: a banking presence in Syria can support project execution by improving payment channels and financing options for contractors and suppliers.