Editor’s Note
This analysis examines the legal and political complexities surrounding the recent announcement of a U.S. policy shift on Syria, highlighting the significant legislative hurdles that remain.
In a sweeping policy reversal unveiled in Riyadh on May 13, 2025, President Trump pledged to lift the entire U.S. sanctions regime on Syria.
Although the Trump administration seeks quick sanctions relief for President Ahmed al-Sharaa’s new Syrian government, executive action alone cannot singlehandedly eliminate the Syrian sanctions program due to its current statutory framework. In particular, the Caesar Syria Civilian Protection Act of 2019 (the “Caesar Act”) requires congressional action for any significant lifting of Syria-related restrictions and would thereby restrict the Trump administration’s plans to lift all sanctions against Syria. Organizations and individuals interested in doing business with Syria will therefore need to carefully navigate the sanctions regime, taking care to comply with all applicable sanctions until they are fully lifted.
In addition, the lifting of sanctions on Syria will not necessarily impact specific individuals and entities located in Syria on the Specially Designated Nationals and Blocked Persons (“SDN”) List, especially those sanctioned under other sanctions programs (e.g., the Russia sanctions program or under the Counter Terrorism sanctions program). Parties engaging in transactions involving Syria will need to continue to engage in proper due diligence when engaging in transactions involving Syria.
There is uncertainty as to whether policy changes would affect only economic sanctions or also the stringent export controls currently imposed on Syria by the U.S.
The European Union (“EU”) and the United Kingdom (“UK”) have also coordinated a gradual and conditional easing of sanctions on Syria, including removing certain entities from asset freeze lists, suspending some sectoral sanctions, and partially lifting financial restrictions to support Syria’s political and economic recovery. However, significant restrictions remain in place, and both jurisdictions retain the flexibility to reimpose sanctions, if necessary.
On May 13, 2025, U.S. President Donald Trump announced that he will “order the cessation of sanctions against Syria in order to give them a chance at greatness.” The policy shift, revealed during a speech at a Saudi-U.S. investment forum in Riyadh on May 13, 2025, was framed as a direct response to appeals from Saudi Crown Prince Mohammed bin Salman and Turkish President Recep Tayyip Erdogan to bolster the interim government led by President Ahmed al-Sharaa, the former insurgent commander who helped oust Bashar al-Assad on December 8, 2024. As of yet, however, no sanctions have actually been lifted by the U.S.
Although the Trump administration seeks to provide quick sanctions relief to the new Syrian government, a presidential executive order or action by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) would not be able to completely do away with the current Syrian sanctions program – in part due to the U.S. statutory scheme in place that requires congressional action.
The Caesar Act, the principal U.S. statutory framework that, since being enacted in December 2019, has authorized secondary sanctions on entities supporting the former Assad regime with the primary purpose being to address and deter human rights abuses committed by the Syrian government, particularly those involving violence against civilians during the Syrian civil war. The wholesale lifting of Syria-related restrictions would, as a matter of law, require either the exercise of suspension authority under the Caesar Act or congressional action to amend or repeal it. The Caesar Act’s significance therefore looms large in determining how – and how quickly – the administration can translate its policy intent into legally effective relief.
The Caesar Act mandates that the U.S. government impose sanctions on a foreign person that:
