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OFAC Releases General License Alleviating Sanctions on Syria

Washington, D.C. (June 6, 2025) - On May 23, 2025, the Office of Foreign Assets Control (OFAC) released General License 25. General License 25 is the most sweeping sanctions alleviation license published by OFAC regarding Syria, and follows President Trump’s May 14, 2025, Riyadh speech announcing the cessation of sanctions against Syria.

In contrast to previous licenses issued by OFAC regarding Syria making certain transactions no longer prohibited, General License 25 alleviates in whole transactions prohibited by several regulatory schemes such as the

  • Syrian Sanctions Regulations;
  • Weapons of Mass Destruction Proliferators Regulations;
  • Global Terrorism Sanctions Regulations;
  • Foreign Terrorist Sanctions Regulations; and
  • Executive Order 13574 of May 23, 2011.

While there are some limited exceptions to the scope of General License 25, such as maintaining prohibitions on individuals and entities on the Specially Designated Nationals List, General License 25 clarifies that transacting with the Government of Syria, including Syrian President Ahmed Al- Sharaa, his government, the individuals in Annex I (appended to General License 25), and related entities, is permissible. In summary, General License 25 seeks to permit:

  • The provision of services to people and companies in Syria;
  • New investment in Syria;
  • The import of or dealing in petroleum and petroleum in products from Syria;
  • Transactions with the new Government of Syria;
  • Transactions with the individuals and entities that are on the Specially Designated Nationals List, but exempt per Annex 1 to General License 25.

As a result, investors and stakeholders can now invest in telecommunications-related services; power grid infrastructure rehabilitation and other energy related services; health care-related services; education-related services; agricultural-related services; civil-aviation and other transportation services; construction-related services; water and waste management-related services; and financial and investment services. U.S. based banks are permitted to process transactions for any activities permitted by General License 25.

On May 28, 2025, OFAC also issued a fact sheet clarifying additional issues concerning General License 25.

The U.S. Department of State issued a waiver on the Congressional Mandated Caesar Sanctions. The Caesar Sanctions, resulting from the Caesar Syria Civilian Protection Act, target Syrian sectors relating to infrastructure, military maintenance, and energy production. The Caesar Sanctions were imposed as a consequence of humanitarian concerns with Syria’s previous government.

General License 25 and the Caesar Act Waiver Certification offer opportunities for investors and stakeholders to contribute to the rebuilding of Syria after the departure of the Assad regime.

Lewis Brisbois’s attorneys are actively engaged in the wide range of legal issues in this area and are advising clients on managing legal and business risk as events continue to develop at an accelerated pace. For more information, contact the author or editors of this alert. Visit our Ukraine Conflict, International Trade, Export, Import and Investment Controls & National Security Practice page for additional alerts in this area.

Author:

Mamoun Mahayni, Associate

Editors:

Andrew Pidgirsky, Partner and Chair of Ukraine Conflict, International Trade, Export, Import and Investment Controls & National Security Practice

Jane C. Luxton, Co-Managing Partner - Washington, D.C.

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