The Syria sanctions program is administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) and codified primarily at 31 C.F.R. Part 542 (Syrian Sanctions Regulations). It is built on a layered set of authorities, including the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003, Executive Order 13338 (2004), and a series of subsequent executive orders (notably E.O. 13399, 13460, 13572, 13573, 13582, 13606, and 13608) issued under the International Emergency Economic Powers Act (IEEPA) and the National Emergencies Act.
The program historically imposed:
- A broad prohibition on new investment in Syria by U.S. persons.
- A ban on the export or reexport of U.S.-origin goods, services, and technology to Syria (with narrow humanitarian carve-outs).
- A prohibition on importing Syrian-origin petroleum and petroleum products into the United States.
- Blocking of property of the Government of Syria and of persons listed on the Specially Designated Nationals (SDN) List for human rights abuses, support to the Assad government, or links to Iran, Hizballah, and ISIS.
The Caesar Syria Civilian Protection Act of 2019 (enacted as part of the FY2020 NDAA) added secondary sanctions exposure for non-U.S. persons who knowingly provide significant support to the Syrian government, its military, or its reconstruction sector.
OFAC publishes general licenses authorizing certain humanitarian, NGO, telecommunications, and personal remittance activity, and case-by-case specific licenses. Following the fall of the Assad government in December 2024, OFAC issued General License 24 in January 2025 authorizing a broader range of transactions with Syrian governing institutions and certain energy and personal remittance transactions for a six-month window, signaling a partial easing while core blocking measures remained in place.
Compliance turns on the SDN List, the 50 Percent Rule (entities owned 50%+ by blocked persons are themselves blocked), and the scope of active general licenses at the time of a transaction.
Example
In June 2020, the U.S. Treasury imposed the first round of Caesar Act designations under the OFAC Syria sanctions program, targeting Bashar al-Assad, his wife Asma, and several Syrian businessmen and military officials.
Frequently asked questions
Yes, within limits. OFAC maintains general licenses authorizing certain NGO activities, food and medicine exports, personal remittances, and earthquake-related relief, but commercial dealings with blocked persons remain prohibited absent a specific license.
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