EU lifts sanctions against Syria

In response to the fall of the Assad regime, the European Union (EU) has largely lifted its sanctions against Syria.

Regulation (EU) 2025/407 of 24 February 2025 (REG 2025/407) had already suspended large parts of the measures laid down in Regulation (EU) No. 36/2012 (REG 36/2012). At the same time, Implementing Regulation (EU) 2025/408 lifted the financial sanctions against six important Syrian organisations.

By way of Regulation (EU) 2025/1098 of 27 May 2025, the EU has now lifted the previously suspended and all other sector-specific sanctions against Syria, except for measures related to security issues. The aim is to facilitate economic cooperation with Syria, its population and its companies and thus promote the country’s reconstruction. In addition, further natural and legal persons, entities and bodies were removed from the sanctions list through Implementing Regulation (EU) 2025/1094 of the same day. However, restrictive measures in connection with the Assad regime, the chemical weapons sector and illegal drugs trade remain in force.

The EU is acting in unison with the United States, which for its part ended its previous total embargo on 23 May 2025 by issuing Syria General License (GL) 25. Most of the transactions previously prohibited under tare now authorised.

Specifically, the following provisions of REG 36/2012 were removed as of 29 May 2025:

• Art. 1a, introduced through REG 2025/407 for the purpose of temporary suspension of sector-specific sanctions.

• Prohibitions on the import, purchase and transport of Syrian crude oil and petroleum products and the prohibition on the provision of financing or financial assistance in connection therewith (Art. 6, 6a, 6b, 7 in conjunction with Annex IV).

• Prohibitions on the sale, supply, transfer and export of jet fuels and fuel additives and on the provision of technical assistance or brokering services and financing or financial assistance related thereto (Art. 7a in conjunction with Annexes Va and Vb).

• Prohibitions on the sale, supply, transfer and export of key equipment and technology for various sectors of the Syrian oil and gas industry and prohibition on the provision of financing or financial assistance and brokering services in connection therewith (Art. 8, 9, 9a, 10 in conjunction with Annex VI).

• Prohibitions on the sale, supply, transfer and export to the Syrian Central Bank of new Syrian denominated banknotes and coinage, printed or minted in the EU (Art. 11).

• Prohibitions on the sale, supply, transfer, export, import, purchase and transport of gold, precious metals and diamonds as well as prohibitions on the provision of technical assistance, brokering services and financing or financial assistance in connection therewith (Art. 11a, 11b in conjunction with Annex VIII).

• Prohibitions on the sale, supply, transfer and export of luxury goods (Art. 11b in conjunction with Annex X).

• Prohibition on the participation in certain infrastructure projects (Art. 12 in conjunction with Annex VII).

• Financing restrictions for certain companies (Art. 13, 13a).

• Exemptions from personal financial sanctions (Art. 21, 21a, 21b); these are now only regulated in Art.20 and 20a.

• Restrictions on financial services (Art. 23, 24, 25, 25a, 26).

• Landing ban for Syrian cargo aircraft (Art. 26a).

• List of Syrian cultural goods in respect of which Art. 11c lays down trade restrictions (Annex XI); Art. 11c as such remains in force.

The following provisions remain in force:

• Sanctions in relation to goods that might be used for internal repression (Art. 2, 2a, 2b, 2c, 3 in conjunction with Annexes IA and IX).

• Restrictions on monitoring software (Art. 4, 5 in conjunction with Annex V).

• Prohibitions on the provision of technical assistance and financing and financial assistance in connection with military items (Art. 3a, 3b).

Through the amendment of Annex I of REG 36/2012, numerous companies from the media and energy sectors were removed from the sanctions list. However, persons, entities and bodies that were associated with the Assad regime remain listed (Art. 14, 15 in conjunction with Annex II). State bodies, including ministries, are also still sanctioned.

In this context, the newly inserted Art. 15a should be highlighted, which allows the competent authorities of EU Member States to authorise the release or making available of frozen funds or economic resources to the Syrian Ministries of Defence or Interior. In this respect, an authorisation shall be considered granted if the competent authority does not respond to a request within five days.