Commercial Considerations Related to the Shift in Syrian Sanctions Policy

These coordinated international actions signal a cautious but significant shift toward engaging with Syria’s new interim government, led by President Ahmed al-Sharaa, as it seeks to stabilize the country and rebuild its economy. This shift may pave the way for significant economic opportunities, including for those in the energy sector. Given the infancy of the new foreign policy landscape and the significant export restrictions still currently in place, companies considering engagements relating to Syria should understand what is authorized and analyze compliance risks related to potential transactions.

What does GL 25 authorize?

GL 25 authorizes all transactions prohibited by the Syrian Sanctions Regulations, 31 C.F.R. pt. 542, other than transactions involving blocked persons not otherwise identified in GL 25.

The General License also authorizes all transactions with (1) the Government of Syria (defined as including President al-Sharaa and his government), (2) any blocked person listed in the Annex to GL 25 (“Annex A”), or (3) any entity owned 50 percent or more individually or in the aggregate by a blocked person listed in Annex A that are prohibited by the following sanctions regulations:

• The Syrian Sanctions Regulations (31 C.F.R. pt. 542),
• The Weapons of Mass Destruction Proliferators Sanctions Regulations (31 C.F.R. pt. 544),
• The Iranian Financial Sanctions Regulations (31 C.F.R. pt. 561),
• The Global Terrorism Sanctions Regulations (31 C.F.R. pt. 594),
• The Foreign Terrorist Sanctions Regulations (31 C.F.R. pt. 597), or
• Executive Order 13574.

Blocked persons (i.e. persons that are, or are owned 50 percent or more by persons that are, designated on the Specially Designated Nationals and Blocked Persons List administered and maintained by OFAC) listed in Annex A with whom transactions are now authorized include, among others, the Central Bank of Syria, the Syrian Ministry of Petroleum and Mineral Resources, and the Syrian Company for Oil Transport.

Limitations to GL 25

The scope of the General License is limited, and imposes several notable restrictions that must be carefully observed when engaging in transactions. In particular, GL 25 does not authorize: (1) transactions involving blocked persons, or entities owned 50 percent or more by blocked persons, that are not identified in Annex A; (2) the unblocking of any property or interests in property pursuant to any U.S. sanctions; or (3) transactions involving, or conducted for or on behalf of, the governments of Russia, Iran, or North Korea, or related to the transfer of goods, technology, software, funds, financing, or services to or from those countries. Companies should review their activities and counterparties closely to ensure full compliance with these restrictions.

Export Restrictions Remain in Place

Despite this financial sanctions relief, exporters should remain aware that strict license requirements continue to apply to most items subject to the Export Administration Regulations (“EAR”) when destined for Syria. The primary exceptions are for food and medicine classified as EAR99, which are generally not subject to these licensing requirements. GL 25 does not alter these existing export control restrictions regarding exports or reexports of U.S.-regulated items to Syria. Nearly all items — including commodities, software, and technology — continue to require a license for export or reexport to Syria, even on a temporary basis. However, as stated above, during the week of June 10, 2025, BIS indicated that it is actively drafting a rule to remove some of the current export controls on Syria. The rule is still under development and must undergo interagency review before publication. While the exact timing remains uncertain, BIS expects to release the rule soon, potentially within weeks.

Significance for the Energy Industry

As the international trade landscape continues to evolve, the energy sector remains an area of significant focus in foreign policy considerations. The recent Syrian sanctions developments also highlight the energy sector as a key area of focus. The previous imposition of sanctions and export controls on Syria stalled Syria’s significant energy production. Now, under GL 25, dealings with several Syrian entities involved in the energy and natural gas sectors including Sytrol, General Petroleum Corporation, Syrian Gas Company and Syrian Petroleum Company, among others, are authorized, thereby expanding the scope of opportunities for investment in Syria’s energy sector. However, such opportunities remain subject to ongoing regulatory changes. Companies considering engagement must continue to exercise robust due diligence and ensure strict compliance with all applicable U.S. sanctions and export control requirements. The regulatory landscape remains dynamic, and careful monitoring of future developments is essential.

*Jessica Spiers is a summer associate in our Washington office.