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Syria Sanctions

Background

On the 15 March 2011, discontent with the continuing authoritarian rule of Syrian President Bashar al-Assad ignited into protests, during the Arab Spring protests across the Middle East and North Africa. The protests focussed on demands for democracy and against the decades-long rule of the Assad family. At this time Syria was viewed as one of the most restrictive police states in the Middle East and in 2010 was listed as the 6th worst country in the 2010 Press Freedom Index. Following the large-scale protests and pro-democracy rallies across Syria, the Assad government conducted months of violent suppression and crackdowns on its civilians. Resultingly, various arms rebel groups such as the Free Syrian Army and Islamic State of Iraq and the Levant (ISIL) formed across the country and by mid-2012 the situation had escalated into a full civil war. 

The escalation to a civil war saw many rebel groups join the fighting against both Assad and each other. Foreign governments were also involved, with Russia and Iran backing the Syrian government. Different opposition powers were supported by a range of other countries including Turkey, the US and some Gulf Arab states. The war saw rapidly changing frontlines and was often fractured into skirmishes, across territory that was under shifting control. Early on in the conflict Assad crossed a globally recognised redline in using chemical weapons against rebel groups and civilian populations believed to be supporting them. Secret police and political prisons were used extensively throughout the conflict. The war sparked a major refugee crisis with an estimated 6.6 million Syrian people leaving the country and 6.7 million internally displaced. Turkey became the first stop on a migration route that saw the EU emerge as a key destination of choice for those fleeing the conflict. 

Recent Developments

In November 2024, a coalition of opposition fighters launched a major offensive against pro-government forces. The offensive was spearheaded by Hay’at Tahrir al-Sham (HTS) and the Turkish-backed Syrian National Army. The capital Damascus was captured by these forces over the 7th and –8th December leading to the fall of the Assad regime. Assad and his family fled to Russia where they were granted asylum. 

HTS has announced a transitional government and a general amnesty for those conscripted in the Assad forces. Assad’s fall was welcomed by many in the state and amongst many Syrian refugees abroad, but some minority groups, such as Syrian Christians, Druze, Kurds, and the Alawites have expressed concern over their safety in the country. Many are cautious about the ex-affiliation with al-Qaeda and ISIS of HTS. Others in the state are hopeful the rhetoric from HTS is true and the country will become one that is democratic and for the people of Syria.


In December 2024 when the HTS first took over it was originally announced elections would be held in the March of 2025. Later in February 25, Syria’s new de-facto President al-Sharaa stated it would take “between four and five years” to hold presidential elections in the state. Additionally, this time is said to be needed for the writing of a new constitution.


On the 15 March 2011, discontent with the continuing authoritarian rule of Syrian President Bashar al-Assad ignited into protests, during the Arab Spring protests across the Middle East and North Africa. The protests focussed on demands for democracy and against the decades-long rule of the Assad family. At this time Syria was viewed as one of the most restrictive police states in the Middle East and in 2010 was listed as the 6th worst country in the 2010 Press Freedom Index. Following the large-scale protests and pro-democracy rallies across Syria, the Assad government conducted months of violent suppression and crackdowns on its civilians. Resultingly, various arms rebel groups such as the Free Syrian Army and Islamic State of Iraq and the Levant (ISIL) formed across the country and by mid-2012 the situation had escalated into a full civil war. 

The escalation to a civil war saw many rebel groups join the fighting against both Assad and each other. Foreign governments were also involved, with Russia and Iran backing the Syrian government. Different opposition powers were supported by a range of other countries including Turkey, the US and some Gulf Arab states. The war saw rapidly changing frontlines and was often fractured into skirmishes, across territory that was under shifting control. Early on in the conflict Assad crossed a globally recognised redline in using chemical weapons against rebel groups and civilian populations believed to be supporting them. Secret police and political prisons were used extensively throughout the conflict. The war sparked a major refugee crisis with an estimated 6.6 million Syrian people leaving the country and 6.7 million internally displaced. Turkey became the first stop on a migration route that saw the EU emerge as a key destination of choice for those fleeing the conflict. 

Why are there sanctions?

Sanctions have been utilised in Syria since the outbreak of the civil war in 2011. Sanctions on were first implemented by the US as the war broke out, with President Obama issuing an Executive Order to block the property of those involved in the government response to the civil unrest and then violations of international norms during the civil war. Canada adopted sanctions next, followed by the EU (including the UK at the time) who put sanctions in place on the trade of goods that could be used for the repression of the civilian population. 


These were significantly bolstered in August 2011 when the US placed an embargo on the oil sector, freezing the financial assets of a number of Syrian ‘big personalities’ and on the Syrian state itself. Countries in Europe and the Middle East followed suit and placing sanctions on Syria. 

In March 2017 the UN announced its intention to sanction Syria for its use of chemical weapons in the territory. When the time came to vote for this resolution, Russia and China vetoed it. Despite this clear crossing of the internationally understood red line on chemical weapons use sanctions at the UN could not be agreed, due to Russian interests in the country.


The primary intent of sanctions on Syria was to prevent the Syrian government from employing violence against its citizens and to motivate the government into political change.


Until the fall of Assad in December 2024, substantial sanctions on Syria remained in place. Since the fall there have been moves to ease sanctions to help the country recover from the civil war and encourage the new government to follow a moderate, multicultural and open society. Nevertheless, the sanctions picture in Syria remains complex, and significant risk remains.

Who has sanctions in place and what type?

Many states around the world have sanctions on Syria, most stemming from the period of Bashar-al Assad’s regime. Despite the change of leadership, with the fall of the Assad regime, many sanctions have remained in place, and will likely continue until there is clarity over the direction the new government in Syria will take on a number of issues, such as inclusion. Some states have begun to announce measures ease the effects of sanctions on civilians and the government in Syria, utilising licenses, and revocations. States such as Canada and Australia also have sanctions on Syria though these are now also subject to the changes occurring.


UK: UK sanctions on Syria came into effect on the 31 December 2020 when the UK formally left the EU. The measures included designations of persons and entities, financial sanctions, including asset freezing, trade sanctions and immigration sanctions.


US: Since the revolution began in March 2011 the US government has applied sanctions on Syria aiming to stop violence against civilians and to pressure the regime to allow for a democratic transition for the Syrian people. Sanctions from the US include financial sanctions, trade sanctions (significantly routed in the Syrian oil trade) and immigration sanctions.


EU (and EU accession countries): The EU introduced sanctions on Syria in February 2012 concerning the energy sector, the supply of arms and the financial sector. In June 2012 several non-Eu accession states also joined the EU’s sanctions on Syria. The EU regime includes financial sanctions, immigration sanctions and trade sanctions. Until the fall of Assad, the EU continued to apply sanctions on the regime. On the 24 February 2025 the EU announced they are to suspend restrictive measures on key economic sectors in Syria. 

The following US/UK General Licences apply to Syria

UK: OFSI General Licence INT/2025/5810196.

On 12 February 2025 OFSI issued a General Licence under the Syria regime which allows for payments to be made in respect of relevant humanitarian assistance activities. The licence requires any person using the licence must provide written notice to HM Treasury within 30 days of commencing the activity.

https://assets.publishing.service.gov.uk/media/67acc69388ce626360cd21cc/Syria_Humanitarian_GL_INT.2025.5810196.pdf(accessed 09 April 2025)


US: General License NO 24

On 6 January 2025, OFAC issued a General Licence authorising transactions with governing institutions in Syria and certain transactions related to Energy and Personal remittances. The GL authorised transactions with: 

  • Governing institutions in Syria following December 8, 2024. 
  • Transactions in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products, natural gas, and electricity, to or within Syria.
  • Transactions that are ordinarily incident and necessary to processing the transfer of non-commercial, personal remittances to Syria, including through the Central Bank of Syria.

https://ofac.treasury.gov/media/933861/download?inline(accessed 09 April 2025)

Syria Updates

Syria Webinars

In this webinar on Syria and sanctions our speakers, Luma Zitani and Ian Bolton, our CEO,  discuss the developments in Syria at the end of 2024 and across the beginning of 2025. They examine the challenges facing the country since the fall of the Assad regime, look at how countries regionally and around the world have responded. They consider the impact on the Syria sanctions regimes and what we might see next. They conclude by looking at and how organisations can best manage the risks. 

UK Syria Regime Infographic Updates

UK Syria Sanctions Update (pdf)Download

Syria Sanctions SOS Resources

Sanctions SOS Whitepaper - The Fall of the Assad Regime (pdf)

Download
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