EU and UK roll back Syria sanctions

Following the fall of the Assad regime in December 2024, both the United Kingdom and the European Union have amended their Syria sanctions regimes to reflect the changed political situation.

On 24 and 25 April 2025, the UK implemented significant amendments to the Syria (Sanctions) (EU Exit) Regulations 2019, including to revoke certain sectoral and financial sanctions and to lift a number of asset freezes, to support Syria’s transition to stability and reconstruction.

Earlier, on 24 February 2025, the EU suspended a range of sectoral sanctions, partially eased financial restrictions and lifted a smaller number of asset freezes, to support an inclusive political transition in Syria and its economic recovery.

Although the exact scopes of the rollbacks differ, with the UK taking further-reaching steps and delisting a longer list of entities, both the UK and EU assert that they have aligned their approach to facilitate Syria’s political transition, humanitarian recovery and economic reconstruction, whilst retaining flexibility to reimpose measures if deemed necessary.

However, the amendments are not complete revocations. Both the UK and EU continue to maintain substantial sanctions programmes targeting Syria. These include a large number of asset freeze measures as well as certain financial and sectoral sanctions restricting particular categories of transactions or activity, for example the transfer of goods or services with military applications or that could be used for internal repression.

Each of the public announcements issued by the UK and EU makes clear that the recent easings are, in part, designed to support the country's humanitarian recovery. This policy objective is reflected in the amendments themselves as well as in the broadened scope of exemptions and/or licences aimed at enabling humanitarian assistance to be delivered. As with the amendments themselves, however, these exemptions and/or licences do not apply universally and some carry specific conditions or obligations, such as reporting requirements. Any organisation considering providing humanitarian support into Syria or for the benefit of Syrian population will still need to consider carefully whether and to what extent these exemptions/licences apply to their activities.

If you would like to further discuss sanctions risk and compliance and how the revised UK and EU Syrian measures may affect your organisation, please contact Chloe Barker, Katie Palms, Daniel Jones, Lydia Rogers, Ignacio Escondrillas or your usual contact in DLA Piper's Global Trade and Government Affairs team.

 

1. United Kingdom

The Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025, in force from 25 April 2025, amend the Syria (Sanctions) (EU Exit) Regulations 2019 (the Regulations).

The updated Regulations reorient their stated purpose towards promoting peace, stability, democracy, and human rights in Syria and ensuring accountability for gross violations committed by or on behalf of the Assad regime.

The Explanatory Memorandum accompanying the changes to the sanctions states that the amendments aim to support Syria’s economic recovery by removing measures on certain sectors that can no longer benefit the former Assad regime, while ensuring the remaining sanctions remain "fit-for-purpose". This includes ensuring that designations relating to "human rights violations committed by members of the now former Assad regime" remain in place or can be imposed quickly for the purpose of accountability.

Amendments to financial sanctions restrictions

The amended Regulations omit all previously imposed investment, financial services and financial markets sanctions, save for prohibitions on buying or selling Assad-era bonds (or providing related services). The Explanatory Memorandum states that these measures are intended to enable financial flows to support the economic recovery of Syria. As a result of these amendments, there are no longer blanket UK sanctions prohibitions on:

• banking in Syria or transacting with banks in Syria;
• opening branches of Syrian banks in the UK;
• allowing Syrian financial institutions to acquire interests in UK financial institutions;
• providing insurance or reinsurance services to the (current) Syrian regime;
• investing in crude oil and electricity production ventures in Syria; and
• buying or selling newly issued Syrian bonds – noting the prohibitions in respect of Assad-era bonds remain in force.

Additionally, asset freezes on 12 Syrian institutions and organisations – including the Ministry of Interior, Ministry of Defence, intelligence directorates, the Army Supply Bureau, and several media companies – were also lifted on 24 April 2025.

These measures followed the 6 March 2025 lifting of asset freezes on 24 Syrian entities, including the Syrian Central Bank, the Syrian Petroleum Company and Syrian Arab Airlines.

Amendments to trade sanctions restrictions

The amended Regulations also lift a number of trade prohibitions, although a number remain in place.

As a result of the amendments, there are no longer blanket UK sanctions prohibitions on:

• the export to Syria of goods related to electricity production;
• the export to Syria of aviation fuel and aviation fuel additives;
• the export to Syria of goods or technology relating to crude oil and natural gas;
• the import from Syria of crude oil and petroleum products; or
• the export of bank notes and coinage to the Syrian Central Bank.

The Explanatory Memorandum states that these measures have been lifted in order to support Syria's economic recovery.

However, a number of trade sanctions remain in place, in consistent scope as before, but in amended form to reflect the regime change. These include UK sanctions on:

• the export to Syria of goods or technology related to chemical or biological weapons;
• the export to Syria of interception and monitoring goods or technology;
• the export to Syria of internal repression goods or technology;
• the import or acquisition from Syria of military goods or technology or arms;
• the export to the Syrian government of gold, precious metals or diamonds;
• the export to Syria of luxury goods; and
• the provision of interception and monitoring services to the Syrian government.

Revocation of aircraft sanctions

The amended Regulations lift all previously imposed sanctions that restricted the movement of aircraft operated by Syrian Arab Airlines and certain Syrian aircraft used for air cargo services.

The Explanatory Memorandum states that the restrictions are no longer necessary as the former Assad regime no longer controls Syrian Arab Airlines and cannot use its aircraft to enable the oppression of the Syrian people.

Humanitarian exceptions and licences

OFSI General Licence INT/2025/5810196, issued on 12 February 2025, has not been amended and remains in force. The General Licence permits certain activities necessary to undertake humanitarian activities that would otherwise breach UK financial sanctions. However, the Licence (1) only applies to certain individuals and organisations; and (2) carries specific terms and conditions, including reporting requirements.

General Trade Licence for Syria Sanctions – Earthquake Relief Efforts in Syria has been revoked, effective 29 April 2025.

 

2. European Union

On 24 February 2025, in support of the political transition in Syria, the Council of the European Union (the Council) decided to suspend a number of sanctions to facilitate engagement with Syria, including to support reconstruction and aid and the return of Syrian nationals to Syria. At the same time, the Council reaffirmed its commitment to maintain sanctions related to the Al-Assad regime and targeting trade in certain sectors and products, such as goods and technology used for internal repression or surveillance.

Council Regulation (EU) 2025/407 (Regulation 2025/407) implemented this decision by amending Regulation (EU) No 36/2012 concerning restrictive measures in view of the situation in Syria. Certain asset freeze measures were also lifted by Council Implementing Regulation (EU) 2025/408 (Regulation 2025/408).

Rollback of sectoral measures

Regulation 2025/407 suspended certain trade sanctions measures and introduced carve-outs for financial sanctions measures related to activity in certain sectors. However, a number of other trade and financial sanctions measures have been left in place.

Specifically, Regulation 2025/407 suspended trade sanctions measures prohibiting:

• the import of crude oil or petroleum products from Syria;
• the supply to Syria of jet fuel and fuel additives;
• the supply to Syria of certain oil and gas equipment and technology;
• the supply to the Syrian Central Bank of new Syrian banknotes and coinage;
• the supply to Syria of equipment used to construct and install electric power plants;
• the provision of financing or investment to Syrian entities exploring, producing or refining crude oil or constructing or installing new electric power plants; and
• the provision of access to EU airports to cargo flights operated by Syrian carriers and all flights operated by Syrian Arab Airlines.

Additionally, Regulation 2025/407 also introduced a number of broad carve-outs to banking restrictions. These carve-outs mean that banking sanctions no longer apply in connection with specific activities, broadly:

• delivering humanitarian assistance or basic services into Syria;
• reconstructing or stabilising, restoring economic activity or institution-building in Syria;
• importing crude oil or petroleum products from Syria into the EU;
• purchasing or transporting Syrian crude oil or petroleum products;
• participating in the construction or installation of new electric power plants;
• selling or transferring jet fuel or fuel additives to Syria;
• providing cargo flights by Syrian carriers access to EU airports; and
• exporting new Syrian denominated banknotes and coinage to the Central Bank of Syria.

However, a number of restrictive measures in Regulation (EU) No 36/2012 remain in force, including sanctions prohibiting:

• the supply to Syria of goods or technology for internal repression;
• the provision of financing or financial assistance relating to Syrian military goods and technology;
• the supply to Syria of technology or software for the monitoring or interception of internet or telephone communications;
• the supply to the Government of Syria of gold, precious metals and diamonds;
• the supply of luxury goods into Syria;
• the transfer of Syrian cultural property goods suspected to have been unlawfully removed from Syria;
• the European Investment Bank from making disbursements or payments on loans with Syria;
• the sale or purchase of Syrian bonds;
• the provision of insurance or reinsurance to Syria or its government; and
• save as permitted by the new carve-outs above, opening bank accounts or branches in Syria, or authorising Syrian banks to open bank accounts or branches in the EU.

Despite some areas of overlap, for example in the energy sector, the EU and UK measures do not exactly mirror one another, with the EU regime currently in force remaining in some respects stricter than the UK regime.

Amendments to asset freeze sanctions

On 24 February 2025, by Regulation 2025/408, the EU lifted asset freezes on the Syrian Central Bank, Syrian Arab Airlines and four other Syrian banks (Industrial Bank, Popular Credit Bank, Saving Bank and Agricultural Cooperative Bank – all of which the UK has now also delisted).

However, the EU has maintained the previously imposed asset freeze on funds and economic resources belonging to, owned, held or controlled by the Syrian Central Bank and located outside of Syria as of 27 February 2012.

The EU, like the UK, has maintained asset freeze measures against a number of individuals and entities linked to the former Al-Assad regime, as well as a number of banks and energy companies that have been delisted by the UK (such as the General Petroleum Corporation, the Syrian Company for Oil Transport, the Syrian Lebanese Commercial Bank and the Agricultural Cooperative Bank).

Humanitarian exceptions and licences

In addition to the rollback of measures, the EU has also extended its existing humanitarian exemptions indefinitely and introduced new ones to support reconstruction and humanitarian efforts in Syria.

 

Relevant instruments and guidance

UK

• The Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025 – see here
• NTE 2025/12: amendments to the Syria sanctions and revocation of general trade licence for Syria sanctions - earthquake relief efforts in Syria – see here
• Syria sanctions: guidance – see here 
• UK bolsters support for Syrian people by amending Syria sanctions – see here

EU

• Council Decision, Regulation and Implementing Regulation concerning restrictive measures in view of the situation in Syria – see here
• Council Decision (CFSP) 2025/406 of 24 February 2025 amending Decision 2013/255/CFSP concerning restrictive measures in view of the situation in Syria – see here
• Regulation - EU - 2025/407 - EN - EUR-Lex – see here
• Implementing regulation - EU - 2025/408 – see here
• Syria: EU suspends restrictive measures on key economic sectors - Consilium – see here
• European Commission's FAQs on EU sanctions on Syria – update of 7 April 2025 – see here

 

How we can help

DLA Piper's International Trade and Government Affairs teams advise on all aspects of sanctions compliance, risk management and engagement with authorities. We can help you assess and navigate Syria-related risks and opportunities, including by:

• Advising on the evolving UK and EU sanctions frameworks relating to Syria and how the changes impact your organisation.
• Assessing opportunities arising from the lifting of restrictions, including through engagement with UK and EU authorities where appropriate.
• Preparing contingency strategies should sanctions be reinstated or amended in response to future developments.