For FIs offering services to money remitters, clarity as to what transactions fall within the bank policies is paramount, especially when the funds transfers are through an intermediary
Money laundering risk: For FIs offering services to money remitters, clarity as to what transactions fall within the bank policies is paramount, especially when the funds transfers are through an intermediary.
In addition, the ability to perform appropriate due diligence on parties in Syria may be severely hindered. Many organizations or businesses in Syria may be newly formed. Understanding whether the organization or business is formed or supported by individuals or entities not supportive of the new government will be difficult as it will be limited to what information the newly formed government is tracking and willing to provide externally. Moreover, instituting controls to determine funds are not going for further credit to governments of Iran, Russia or North Korea, as required by GL 25 and other OFAC sanctions, may prove difficult.
Longevity risk: The U. S. may be a lone horse, at least for a while, in advocating for trade relations with Syria. While the EU and U. K. have also eased some sanctions involving Syria, numerous trade restrictions remain. 15 Remember, in 2023, the U. S. eased sanctions with Syria( GL 23) for six months, but the measures had limited effect since banks and companies were nervous to take the risk. The same may happen today. Revising policies and procedures only to have no takers would be inefficient and perhaps costly. Moreover, FIs must encourage their customers to have an exit strategy and implement an exit strategy for themselves.
Financial risk: There are contractual risks for FIs as certain loan agreements and covenants may contain language prohibiting business with Syria. Therefore, review of both existing and new contracts is warranted to avoid unintended breach by opening up the FI to doing business with the contractually prohibited country.
Conclusion
The decision on whether to permit customers to utilize the provisions of GL 25 is not easy. Simply because an action becomes permissible does not mean the action is feasible operationally or profitable for the FI. For FIs that jump into transactions in / with Syria, there may be serious repercussions. However, for FIs that take a measured approach and price accordingly, Syria may be serious business.
Amy M. Wotapka, CAMS, BSA officer, first vice president, First American Bank, WI, USA, awotapka @ firstambank. com
1
“ Syrian Sanctions Regulations Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain Blocked Persons,” Department of the Treasury, May 23, 2025, https:// ofac. treasury. gov / media / 934306 / download? inline
2
“ Syria Travel Advisory,” U. S. Department of State, July 23, 2025, https:// travel. state. gov / content / travel / en / traveladvisories / traveladvisories / syria-travel-advisory. html
3
Ibid.
For FIs offering services to money remitters, clarity as to what transactions fall within the bank policies is paramount, especially when the funds transfers are through an intermediary
4
“ Prohibitions, Restrictions and Notices, Syria” Federal Aviation Administration, https:// www. faa. gov / air _ traffic / publications / us _ restrictions # Syria
5
“ Syria Sanctions,” U. S. Department of State, https:// www. state. gov / syria-sanctions /
6
“ Caesar Act Waiver Certification,” U. S. Department of State, May 23, 2025, https:// www. state. gov / caesar-act-waiver-certification /
7
“ Clarification to the Export Administration Regulations; General Order to Implement the Syria Accountability and Lebanese Sovereignty Act,” Federal Register, The Daily Journal of the United States Government, February 24, 2006, https:// www. federalregister. gov / documents / 2006 / 02 / 24 / 06-1709 / clarification-to-the-export-administration-regulations-general-order-to-implement-the-syria
8
“ Frequently Asked Questions( FAQs) for Syria General License 25,” The United States of the Treasury, June 30, 2025, https:// ofac. treasury. gov / media / 934311 / download? inline
9
“ Fact Sheet: Implementing the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003,” The White House, May 11, 2004, https:// georgewbush-whitehouse. archives. gov / news / releases / 2004 / 05 / 20040511-7. html
10
“ United States Eases OFAC Sanctions on Syria,” Latham & Watkins LLP, May 27, 2025, https:// www. lw. com / en / insights / united-states-eases-ofac-sanctions-on-syria
11
“ Office of Antiboycott Compliance( OAC),” Bureau of Industry and Security, https:// www. bis. doc. gov / index. php / enforcement / oac
12
“ List of Countries Requiring Cooperation With an International Boycott,” Federal Register, The Daily Journal of the United States Government, April 25, 2025, https:// www. federalregister. gov / documents / 2025 / 04 / 25 / 2025-07149 / list-of-countries-requiring-cooperation-with-an-international-boycott
13
“ OCC Ceases Examinations for Reputation Risk,” Office of the Comptroller of the Currency, March 20, 2025, https:// www. occ. gov / news-issuances / news-releases / 2025 / nr-occ-2025-21. html
14
“ Reporting, Procedures and Penalties,” Federal Register, The Daily Journal of the United States Government, September 13, 2024, https:// www. federalregister. gov / documents / 2024 / 09 / 13 / 2024-20674 / reporting-procedures-and-penalties
15
Sara Nordin, Ed Pearson and Emma Pessotto,“ Status update: EU and UK easing of sanctions on Syria,” White & Case LLP, June 30, 2025, https:// www. whitecase. com / insight-alert / status-update-eu-and-uk-easing-sanctions-syria
ACAMS Today | September – November 2025 95