EU lifts sanctions against Syria

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

Regulation (EU) 2025/407 of 24 February 2025 (Regulation 2025/407) already suspended large parts of the measures enshrined in Regulation (EU) No 36/2012 (Regulation 36/2012). At the same time, Implementing Regulation (EU) 2025/408 lifted the financial sanctions against six significant Syrian organizations. Regulation (EU) 2025/1098 of 27 May 2025 lifted the previously suspended sanctions as well as all other sector-specific sanctions against Syria, with the exception of measures based on security concerns. The aim is to facilitate economic cooperation with Syria, its people, and its businesses, thereby promoting reconstruction. Furthermore, Implementing Regulation (EU) 2025/1094, issued on the same day, removed additional natural and legal persons, organizations, and entities from the sanctions list. However, restrictive measures relating to the Assad regime, the chemical weapons sector, and the illicit drug trade remain in force. The EU is thus acting in concert with the United States, which itself ended its total embargo on May 23, 2025, by enacting the Syria General License (GL) 25. Most of the transactions previously prohibited under the Syrian Sanctions Regulations are now permitted.

Specifically, the following provisions of Regulation 36/2012 were deleted with effect from 29 May 2025:

• Article 1a, introduced by Regulation 2025/407 for the purpose of temporarily suspending sector-specific sanctions, is repealed.

• Import, purchase and transport bans on Syrian crude oil and petroleum products, and the ban on providing financial resources or assistance in connection therewith (Articles 6, 6a, 6b, 7 in conjunction with Annex IV).

• Sale, supply, transfer and export bans on aviation turbine fuels and fuel additives, and the ban on providing technical assistance or intermediary services and financial resources or Financial assistance in this regard (Art. 7a in conjunction with Annexes Va and Vb).

• Sales, supply, transfer and export bans on key equipment and technology for various sectors of the Syrian oil and gas industry, as well as a ban on the provision of funds or financial assistance and intermediary services in this regard (Art. 8, 9, 9a, 10 in conjunction with Annex VI).

• Sales, supply, transfer and export bans on new banknotes and coins denominated in the Syrian national currency, printed or minted in the EU, to the Syrian Central Bank (Art. 11).

• Sales, supply, transfer and export bans, as well as import, purchase and transport bans on gold, precious metals and diamonds, and a ban on the provision of technical assistance or intermediary services, as well as funds or financial assistance in this regard (Art. 11a, 11b in conjunction with Annex VIII).

• Sales, supply, transfer and export bans for luxury goods (Art. 11b in conjunction with Annex id="">• Exceptions to personal financial sanctions (Art. 21, 21a, 21b); These are henceforth only regulated in Articles 20 and 20a.

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

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

• List of Syrian cultural property in relation to which trade bans exist pursuant to Article 11c (Annex XI); Article 11c as such remains in force.

However, the following provisions remain in force:

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

• Restrictions on surveillance software (Articles 4, 5 in conjunction with Annex V).

• Prohibition on the provision of technical assistance and the provision of funds and financial aid in connection with military equipment (Articles 3a, 3b).

Furthermore, the recasting of Annex I to Regulation 36/2012 removed numerous companies from the media and energy sectors from the sanctions list. However, individuals, organizations, and institutions associated with the Assad regime remain listed (Articles 14 and 15 in conjunction with Annex II). State bodies, including ministries, also remain sanctioned. In this context, the newly inserted Article 15a is particularly noteworthy, as it allows the competent authorities of EU Member States to authorize the release or provision of frozen funds or economic resources to the Syrian Ministry of Defense and the Ministry of the Interior. In this respect, a deemed authorization is provided: if the competent authority does not respond to a corresponding application within five days, authorization is deemed to have been granted.