States Have Profited from the Conflict in Syria. They Should Use Those Profits to Establish the Syria Victims Fund
States Have Profited from the Conflict in Syria. They Should Use Those Profits to Establish the Syria Victims FundStates have collected over USD 1 billion from violations linked to the conflict in Syria. In 2022, French cement company Lafarge paid the United States USD 778 million in fines and forfeitures after pleading guilty to conspiring to provide material support to designated terrorist organizations, the Islamic State and al-Nusra Front. In 2021, a Danish court issued fines and confiscations totaling over USD 7 million against Bunker Holding, its executive, and a subsidiary, for breaching EU sanctions by delivering jet fuel used by Russia in Syria. In 2019, a Belgian court collected fines totaling EUR 350,000 from three companies and two managers who shipped precursors for chemical weapons to Syria without necessary licenses. That same year, UK authorities fined a telecom company GBP 146,341 for breaching UK sanctions on Syria and separately seized over GBP 24,000 from a bank account held by Bashar al-Assad’s niece, due to money laundering and sanctions evasion. These are just some of the cases that have been identified so far.
These fines, penalties, and forfeitures are generally deposited into national bank accounts and used for unrelated domestic purposes—allowing governments to profit from violations in Syria. No state should materially benefit from these harms. Instead, states should redirect Syria-linked financial recoveries to benefit victims and survivors.
Syria Victims Fund Design
My team at the Atlantic Council Strategic Litigation Project has been working with Syrian civil society partners to develop a proposal for the Syria Victims Fund (SVF)—a mechanism to ensure that proceeds from legal actions related to Syria’s conflict are redirected to benefit victims and survivors of international law violations. Last year, we convened a working group of 19 diverse Syrian civil society leaders, victim representatives, and experts to discuss the design of the SVF. Through a series of online discussions and an in-person workshop, the group developed a policy brief that lays out recommendations on host and governance structure, funding sources, beneficiaries, and types of support for the SVF.
By consensus, the working group agreed that the EU should establish and host the SVF, with non-EU Member States able to join through agreement. (Alternatively, the SVF could be established through the United Nations or a multilateral agreement between states.) Participating states would then deposit Syria-linked forfeitures, fines, and penalties into the SVF, for distribution to benefit victim communities. The SVF should not receive Syrian state assets or judgments awarded to individual victims, as these belong to the Syrian population and individual victims, respectively. The SVF should take a victim-centered approach and include monitoring and advisory roles for victims and survivors. It should also collaborate with trusted Syrian civil society and international organizations, to ensure efficiency and prevent duplication of efforts.
The working group recommends an inclusive approach to defining victims, covering any victim of international law violations committed in Syria by any perpetrator since 2011. However, recognizing the vast number of victims and limited resources, the SVF should identify priority communities and areas for support, focusing on the most vulnerable groups, and periodically re-evaluate those priorities. To maximize the number of beneficiaries served, the SVF should provide collective support—for example, physical and mental health services, education, livelihoods, and legal aid—targeted to address harms that resulted from international law violations. Support could be provided through local and international organizations with a track record of serving victim and survivor communities in Syria and a commitment to a victim-centered approach.
The SVF could also support longer-term, more comprehensive transitional justice efforts—for example, mapping violations, building a victim registry, and developing national capacity for victim registration, documentation, and verification.
International Momentum for the Syria Victims Fund
The SVF proposal aligns with European Parliament recommendations. In 2024, the Parliament called on EU Member States “to establish a European fund for victims of serious violations of international law in Syria … by identifying existing funds linked to violations of international law in Syria within their jurisdictions, such as monetary judgments, sanctions, fines and penalties, forfeiture orders, funds frozen as they are linked to property unlawfully acquired by the Syrian regime, and other revenue” and to design the fund “in full cooperation with the families of the victims.” The Parliament reiterated this call in 2025, “invit[ing] the EU to explore pathways to use frozen assets of the Assad regime for a trust fund for Syrian reconstruction, rehabilitation, and compensation of victims.”
The SVF also builds upon creative efforts to redirect Russian assets to benefit Ukraine. In 2024, the United States transferred USD 500,000 in Russian-linked assets to Estonia, “for the express purpose of assisting Ukraine.” These funds were collected through a criminal forfeiture, the same modality by which Lafarge paid hundreds of millions to the United States. In addition, Ukraine has received part of the revenue generated from frozen Russian state assets’ investments, as well as loans to be repaid from revenue generated from frozen Russian state assets. Belgium has also announced that it would repurpose the tax it collects on Russian state assets—USD 2.3 billion in 2024—to benefit Ukraine. The EU has also established the Ukraine Facility, a funding mechanism that has so far directed over EUR 19 billion to Ukraine and is financed by the EU annual budget and EU bonds.
State Action is Needed
As the EU Parliament has highlighted and many states have acknowledged, there remains a pressing need to increase support for vulnerable Syrians, including victims of international law violations. Efforts on Ukraine clearly demonstrate that states have the means to redirect proceeds to benefit victim communities; where existing tools are insufficient, they are inspired to develop new ones. Syrian civil society is simply calling on states to support Syrians, just as they support Ukrainians.
States committed to supporting transitional justice, victims, and survivors should take concrete action to lay the groundwork for the SVF. They should offer diplomatic backing for establishing the SVF—for example, through public statements of support and closed briefings to socialize the concept among likeminded states, including at the European Council. They should also pledge voluntary contribution to finance the establishment and operation of the SVF. States collecting monetary judgments linked to violations in Syria should review their national legislative and policy frameworks to determine whether changes are needed to redirect money to the SVF. Where changes are necessary, they should be implemented; where frameworks already allow it, Syria-linked sums should be earmarked for the SVF. Existing United Nations and other international bodies supporting accountability for Syria should also offer technical expertise and advisory support to guide the SVF’s design and foundational stages, and later commit to information sharing during the SVF’s operation.
One Component of Transitional Justice
Syria is at a pivotal moment. After 13 years of war and decades of dictatorship and repression, there is finally an opportunity to ensure justice and accountability. That process will take time: the Syrian transitional government is still establishing itself, the National Commission for Transitional Justice is only a few months old, and the judiciary requires rebuilding to ensure due process and rule of law. Syria must develop a national transitional justice program that addresses all violations from the conflict, regardless of perpetrator, and ensures the full, meaningful, and equal participation of a diverse Syrian civil society. The process should also ensure victims’ right to reparation, which includes the restoration of rights, rehabilitation, compensation, satisfaction, and guarantees of non-repetition.
While holistic transitional justice programs are being established, victim communities need immediate support. The Syria Victims Fund can provide such support, helping victims begin their recovery process while paving the way for longer-term justice and accountability. Delaying support risks further marginalizing victims, while acting now mitigates ongoing harm and empowers victims to continue their fight against impunity.