SANCTIONS
Getting serious about Syria
On May 23, 2025, the Office of Foreign Asset Control( OFAC) issued General License( GL) 25 1 permitting previously prohibited activity in Syria and with the new government of Syria. While some activities are now permissible, many activities remain prohibited. The press surrounding the issuance of the GL makes it sound like Syria is open for business. While certain activities are permissible, they are not without risk to businesses and financial institutions( FIs).
For example, take personal and business travel. As of March 2025, the U. S. government continued to urge U. S. citizens not to travel to Syria for any reason 2 due to the risks of terrorism, kidnapping, armed conflict and unjust detention. Further, the U. S. government“ is unable to provide any routine or emergency consular services to U. S. citizens in Syria.” 3 The government warning goes on to describe an increase of bombing incidents. Finally, the Federal Aviation Administration continues to enforce certain flight restrictions within Syria. 4
Another example is exports. The“ Note” in GL 25 states:“ Nothing in this general license relieves any person from compliance with any other Federal laws or requirements of other Federal agencies, including the International Traffic in Arms Regulations( ITAR) administered by the Department of State and the Export Administration Regulations( EAR) administered by the Department of Commerce.” A quick glance at the Department of State website 5 provides little additional guidance. While the Department of State website references the waiver under the Caesar Syria Civilian Protection Act 6 cited in GL 25, there is no information encouraging trade with Syria ― other than the humanitarian efforts which were permissible prior to the issuance of GL 25. Inputting Syria into the search bar of the U. S. Department of Commerce site returns“ Sorry, no results found for Syria” with the first related item being a Federal Register entry from 2006. 7 While GL 25 appears to open Syria to travel, trade and other commerce, the guidance and infrastructure to support activities was not available at issuance. FIs must understand the risks of doing business in Syria and / or with the new Syrian government prior to reaping the rewards of this potential new income stream. Conducting a risk assessment is a must as there are hidden operational risks that must be considered. These operational risks( like the 10-year retention for all transactions under GL 25) will come at a cost. Consider the below prior to processing transactions related to Syria.
92 acamstoday. org