Syria sanctions : implications for European companies

Information updated as of 21 November 2025 and subject to change.

EU Sanctions on Syria

Economic sanctions against Syria were lifted on May 20, 2025, following a partial lifting on February 24, 2025.

This means the lifting of all economic measures imposed since 2011, with the exception of those based on security concerns. This lifting is formalized in Council Implementing Regulations 2025/1094 and 2025/1095.

Specifically: there is no longer a ban on investing in key sectors: restrictions on oil, gas, electricity, telecommunications, metals, and transport have been lifted. The financial embargo on the Syrian central bank and major banks has also been suspended.

Numerous exceptions to this lifting of sanctions remain in place:

- Restrictions on dual-use goods

- Sanctions targeting individuals responsible for crimes

- Counter-terrorism sanctions

- Sanctions for serious human rights violations

- Sanctions against those who fuel instability, repression, and corruption

- Sanctions against associates of the former regime (318 individuals and 58 entities sanctioned)

All European companies must verify that they do not have any partnerships with these entities. (The entities still subject to sanctions are listed in Regulation No. 36/2012 - 2025)

Sectoral sanctions have been removed, however targeted sanctions remain and continue to be a significant obstacle to investment. Indeed, many targeted sanctions target key sector actors. This creates a barrier even in the absence of sectoral sanctions.

Secondary sanctions

US sanctions, particularly the Caesar Act and OFAC sanctions, expose European companies to sanctions for any partnerships with sanctioned Syrian entities (individuals and companies).

The Caesar Act (Caesar Syria Civilian Protection Act) : the Senate approved a six-month waiver of the law (subject to continued compliance with certain conditions). Pending its complete repeal by the House, with no set timeline, the Caesar Act remains a significant obstacle for businesses. Targeted sanctions remain in effect. The waiver remains temporary and conditional.

The Office of Foreign Assets Control (OFAC) has lifted territorial sanctions but maintains sanctions against entities and individuals (as of May 23, 2025, with the issuance of General License 25). European companies wishing to export products containing US components (US content, software, and technology) to Syria must comply with export regulations (Export Administration Regulations EAR 12 CFR 730-774). Beyond a minimum threshold of US components, a Bureau of Industry and Security (BIS) license is required. Restrictions remain, including a ban on transactions that benefit Russia, Iran, or North Korea. The risk of the US nexus, involving the use of the dollar and the involvement of a US entity, remains a significant point to monitor.

The United States is reviewing its designation of Syria as a State Sponsor of Terrorism (a review is possible in early 2026). In the meantime, additional restrictions remain in place.

The UN lifted sanctions against the Syrian president in November (UN Resolution 2729), as did the United States with the removal of Ahmed Al-Charaa from its terrorist list. The Syrian President have been removed from the sanctions list targeting individuals and groups linked to the Islamic State and Al-Qaeda, which were subject to a travel ban, asset freeze and arms embargo.

The United Kingdom also revoked HTS's terrorist organization status in October, following the US in July. However, the UK maintains targeted sanctions against Syria.

Conclusion

The overlapping sanctions regimes, whether EU, UK, or US, create a significant operational risk.

Further attention must be paid to products with US origin components and the risk of the US nexus, which can trigger liability. It is also essential to ensure that you have the necessary EU or US licenses for certain products.

The risk of sanctions snapback should never be ruled out, depending on developments on the ground.

In this context, European companies wishing to operate in Syria must monitor applicable sanctions and implement enhanced due diligence on their partners there. This involves analyzing the beneficial owners of partners, intermediary networks, and business structures, among other things, to ensure they are not on sanctions lists and to eliminate the risk of sanctions violations.

Sources:

EU sanctions on Syria:

-Council Implementing Regulation (EU) 2025/1094 – amends EU Syria sanctions. Link

-Council Implementing Decision (CFSP) 2025/1095 – implements CFSP decision on Syria sanctions. Link

-Council of the EU press release (28 May 2025) – lifts economic sanctions except security based restrictions. Link

US sanctions / Caesar Act / OFAC:

-OFAC General License 25 (23 May 2025) – authorizes many transactions previously prohibited. Link

-OFAC press release (30 June 2025) – revocation of Syria sanctions. Link

-White House Executive Order revoking Syria sanctions (30 June 2025). Link

UK sanctions / HTS:

-UK government announcement (21 October 2025) – HTS removed from terrorist organisation list. Link

UN sanctions:

-UN Security Council Resolution 2799 (6 Nov 2025) – removes Syrian President Ahmed Al‑Charaa from the sanctions list. Link