US Sanctions Legislation Up in the Air?

US policymakers are currently considering two pieces of sanctions legislation for Syria—both of which could have critical impacts on the activities of the Assad regime, the political process, and the broader population. The first relates to the Caesar Act, set to expire in less than a month on 20 December; the second is the Anti-Normalization Act, which passed Congress early this year and was most recently re-introduced as the “Supporting Syrian Civilians Act.”

Syria has been under US sanctions since 1979. However, following the 2011 uprising and Assad’s brutal crackdown on protesters, the Obama administration expanded the sanctions considerably, including under the 2019 Caesar Act. Through targeting specific economic sectors, companies, and individuals, sanctions aim—in principle—to non-violently pressure Assad to halt attacks on the Syrian people and take steps toward a political settlement to the conflict.

The Caesar Act, passed under the previous Trump administration, further broadened sanctions on Syria by enforcing penalties against individuals and companies doing business with the regime in multiple sectors, including reconstruction, through the use of secondary sanctions.

“The Caesar Act is the only major political win of the revolution,” said Mouaz Moustafa, the director of the Syrian Emergency Task Force (SETF), which advocates for the Syrian people in Washington. “Support for Caesar is strong in Congress, across the board, [among] Republicans and Democrats and in the House and the Senate,” Moustafa said.

The Caesar Act is expected to be renewed through the same avenue it was originally passed in 2019, an annual defense policy bill known as the National Defense Authorization Act (NDAA). Although Senate leaders filed the NDAA package for 2025 on 20 September, Caesar could still be “air-dropped” into the legislation and passed in December with the consensus of Senate and House leaders.

Although this is looking increasingly unlikely, Moustafa reiterated, "Caesar is safe to be renewed — either now or a little bit later, either through the NDAA or alternative avenues before the year’s end.”

Assad Regime Anti-Normalization Act of 2023

Under debate are provisions of a new bill known as the “Assad Regime Anti-Normalization Act of 2023-24.” The bill passed in the House on 14 February 2024, and has since been under scrutiny in the Senate, with many Syrian-Americans advocating for its passage in NDAA 2025. On 11 September, the bill was re-introduced as the “Supporting Syrian Civilians Act” (SSCA). One of its articles calls for extending Caesar until 31 December 2028. But the Act includes much more, such as a “non-recognition” clause to affirm the US’s opposition to normalization with the Assad regime. 

“We’re very interested in getting the Anti-Assad Normalization Act passed because it addresses many of the loopholes that Caesar, and US policy in general, has regarding Syria, which the Assad regime and its allies have used to build their financial and policy empire on its ruins,” said Dr. Muhammad Bakr Ghbeis, board member and former president of Citizens for a Secure and Safe America (C4SSA), a non-profit organization “dedicated to promoting democracy in Syria.”

The bill aims to curb the regime’s diversion of humanitarian aid through the UN and penalizes the expropriation of Syrian land. It also authorizes $20 million in economic assistance and stabilization funding for northwest Syria, including funding for the White Helmets and for countering captagon operations.

Yaser Tabbara, the president of the American Relief Coalition for Syria, said that “Passing the Anti-Normalization Act will increase pressure on Assad, reinvigorate political discussions, and signal US engagement in seeking a collaborative political solution involving regional states considering normalization.” 

Up for Debate 

Leading Syrian–American advocates have expressed their concern over several provisions in the latest amendments to the bill, introduced as the SSCA by Democratic Maryland Senator Ben Cardin on 11 September. Senator Cardin chairs the Senate’s Foreign Relations Committee, where discussions over Caesar are taking place. 

Mohammad Alaa Ghanem, a Syrian advocate in Washington, said: “We believe [Cardin’s amendments] would weaken Caesar and would make its enforcement a lot harder. Although we were open to compromise, the Senator and his staff have not shown willingness to cooperate. Given this situation, we’re holding off, and we would rather take up the bill next year.” 

The deal-breaker for Ghanem was a newly inserted provision that would provide an “extremely broad” humanitarian exception within the Caesar Act, which he and other leading advocates argue could be easily exploited by the regime and its allies.

In a letter addressed to Senator Cardin on 20 September and reviewed by the authors, its signatories—including Ghanem—said that the exemption could exempt many activities currently under sanction and could allow regime actors to argue for the classification of any activity as “necessary for” or “related to” humanitarian efforts—and thereby the bill would “undermine the effectiveness of the Caesar Act.” 

If the exception is not amended, Ghanem prefers to take up the bill next year. “We’d rather have Caesar as is than a weakened Caesar and a weakened Assad Regime Anti-Normalization Act,” he said. 

Humanitarian Aid

Humanitarian organizations, however, have consistently advocated for broader exemptions, as their operations are often hampered by the narrow interpretation of sanctions legislation and the overcompliance of involved actors.

The literature shows how sanctions increase compliance costs for humanitarian organizations, disproportionately affecting smaller—but critical—actors who are often forced to opt out of operating in Syria entirely. Avoiding the numerous indirect channels that could trigger sanctions takes resources and time, increasing compliance costs that many organizations cannot access. 

Sanctions also often mean the due diligence period is extended, elongating the time from when a humanitarian actor initiates a transaction with a Syria-based client and when the transaction is approved. Unless clear general licenses or streamlined humanitarian carveouts apply, actors need to rely on specific authorizations. Obtaining such exemptions from sanctions can lead to project delays, or in some cases the loss of the project altogether.

These humanitarian obstacles are the unintended consequences of decades of sanctions in Syria that are not due to specific sanctions legislation. “[Caesar] has the strongest humanitarian exemptions in any bill—a bill written with the knowledge and understanding that sometimes sanctions can have unintended consequences, SETF director Moustafa stated. The Syrian economy being destroyed, the overcompliance of banks [and other humanitarian obstacles], these things pre-date Caesar,” he argued.

What to Watch

The passage of the Anti-Normalization Act or SSCA appears increasingly unlikely under the current administration. However, the recent flip of the US Senate may help its passage chances next year.

Notably, in the next Congress Cardin will not serve in the Senate, having not sought re-election. Senator James Risch (Republican, Idaho)—a proponent of the Anti-Normalization Act and generally on expanding sanctions on Syria—is poised to take Cardin’s place as chair of the Foreign Relations Committee. 

Furthermore, the appointment of Senator Marco Rubio as Trump’s Secretary of State and Congressman Michael Waltz as an advisor to the National Security Council are expected to play a “promising role” on the Syrian issue and on blocking Assad and his supporters, and will “tighten the noose around the Iranian regime,” Dr. Ghbeis posted on X. However, other potential appointees to the administration, as argued in the external contribution to this issue of Syria in Figures, might move the administration in the opposite direction. For the time being, uncertainty abounds.