U.S. Lifts Most Restrictions on Doing Business in Syria

The Trump Administration has rescinded comprehensive economic sanctions on Syria to support the post-Assad government and Syria’s “path to stability and peace.” Following initial steps to provide sanctions relief in late May, (see our prior alert Economic Sanctions Relief for Syria Provides Opportunities and Risks for U.S. Companies), President Trump issued an Executive Order revoking most of the long-standing restrictions on business in Syria. Effective July 1, 2025, U.S. companies and individuals are generally authorized to engage in business transactions in Syria, including with the Syrian government; while strict export control rules remain, those are likely to also be significantly eased soon.

The lifting of the economic sanctions administered by the Office of Foreign Assets Control will allow the two-way flow of investment, services and goods not subject to export controls. As well, of relevance to non-U.S. companies, the Executive Order also directs the Secretary of State to examine the potential suspension of so-called “secondary sanctions” authorized under the Caesar Syria Civilian Protection Act.

Other Executive Order measures pave the way for a significant easing of U.S. export controls. The Executive Order waives the requirements of the Chemical and Biological Weapons Act, which will have the effect of easing a number of controls on the export of sensitive goods to Syria. The Executive Order also calls for a review of Syria’s long-held status as a State Sponsor of Terrorism. If that status is lifted, it will likely result in the further easing of export control rules.

Some targeted sanctions remain, including on the Assad family and their associates, captagon traffickers, and persons in Syria associated with ISIS, Al Qaeda and Iran and its proxies.

Implications

With this action, comprehensive economic sanctions remain only on Cuba, Iran, North Korea, and Russian-controlled areas of Ukraine. Most recent sanctions programs eschew a comprehensive sanctions approach, adopting a strategy of targeting areas of higher revenue (such as the energy sectors in Russia and Venezuela).

The lifting of the Syria sanctions present new opportunities for U.S. companies as well as non-U.S. companies with U.S. ties. However, risks remain that highlight the importance of a well-calibrated compliance system. In addition to targeted sanctions on certain parties and some export restrictions, Syria has historically been marked by consistent corruption, and has also been a strong proponent of the Arab boycott of Israel. Accordingly, companies operating in Syria should assess the adequacy of their compliance with anti-corruption laws and the U.S. antiboycott laws.

This memorandum is a summary for general information and discussion only and may be considered an advertisement for certain purposes. It is not a full analysis of the matters presented, may not be relied upon as legal advice, and does not purport to represent the views of our clients or the Firm. Greta L. Nightingale, an O’Melveny partner licensed to practice law in the District of Columbia; David N. Kelley, an O’Melveny partner licensed to practice law in New York and Connecticut; and David J. Ribner, an O’Melveny partner licensed to practice law in the District of Columbia and New York, contributed to the content of this newsletter. The views expressed in this newsletter are the views of the authors except as otherwise noted.

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