Origins of U.S. Sanction Policy Toward Syria
The first significant pressure from the U.S. on the Syrian leadership began in the early 2000s, following the events of September 11, 2001. On May 11, 2004, President George W. Bush signed Executive Order No. 13338, which initiated targeted sanctions against the Syrian government. Since then, sanctions have been repeatedly expanded, especially against the backdrop of the civil war that started in 2011 and numerous human rights violations. Regulations are regularly updated to reflect changes in the geopolitical situation and new challenges. For conducting business or interacting with Syria, support from experienced lawyers specializing in OFAC regulations is critically important.
Why Were Sanctions Imposed on Syria?
Syria has been under international sanctions for more than a decade. The main reason is the regime’s policies associated with brutal actions during the civil war and systematic human rights abuses. Sanctions imposed by the U.S., the European Union, and several other countries aim to restrict the Syrian government’s resources and encourage political change. The financial sector, trade, and energy are among the key areas restricted to reduce the regime’s ability to sustain military operations and suppress the population.
Tightening Sanctions After the Start of the Civil Conflict
After the outbreak of the war in Syria in 2011, the international community significantly intensified measures against the Bashar al-Assad regime. The main sanctioning parties were the U.S. and the EU, imposing the following restrictions:
- Asset freezes on senior officials, military personnel, and organizations supporting the regime;
- Trade embargoes — bans on export and import of certain goods, including weapons and dual-use technologies;
- Financial restrictions — blocking international operations of Syrian banks, prohibition of investments in the country’s economy.
The goal of these measures was to economically and diplomatically isolate the regime to force it to negotiate and cease hostilities. Despite sanctions, the conflict continued, leading to additional restrictions and expanded lists of sanctioned persons and entities.
The 2023 Turkey-Syria Earthquake: Impact on Sanctions
The February 2023 earthquake that struck Turkey and Syria raised humanitarian concerns related to sanctions. Many voices called for easing or temporarily lifting restrictions to facilitate aid delivery to those affected. Critics noted that sanctions complicated humanitarian operations, while supporters pointed out the existence of special humanitarian exemptions.
In response, the U.S. issued General License No. 23, allowing certain transactions related to earthquake relief. However, the ban on oil-related operations and dealings with sanctioned persons limited the scale of support. This case demonstrated the complexity of balancing pressure on the regime with urgent humanitarian needs.
What Areas and Sectors Do the Sanctions Cover?
Export Restrictions to Syria
According to OFAC sanctions, the export of a range of goods to Syria is prohibited or strictly limited. This aims to prevent the regime from strengthening its military power and infrastructure:
- Weapons and military equipment, including parts and supplies;
- Equipment and technologies for the oil, gas, and energy sectors;
- Surveillance and communications interception technologies;
- New Syrian banknotes and coins;
- Luxury goods that may be used to reward loyalists;
- Chemicals and materials potentially applicable in the military field;
- Precious metals and stones if acquired by the government or affiliated entities.
Import and Trade Restrictions
Sanctions also prohibit the import and trade of key resources crucial for the regime’s economy:
- Oil and petroleum products;
- Gold, precious metals, and diamonds.
Ban on Commercial Operations
Special attention is paid to the oil and gas and financial sectors:
- Prohibition of investments in the petrochemical industry and creation of joint ventures;
- Ban on selling shares and interests in oil and gas companies;
- Syrian banks are prohibited from opening branches abroad, and foreign banks from establishing correspondent relations with Syrian banks;
- Restrictions on the construction of new power plants.
Service Restrictions
Providing services that may indirectly support the regime is also banned:
- Services related to exporting sanctioned goods;
- Financial services for the import of prohibited goods;
- Investment services for banned sectors;
- Military and intelligence services, including communication monitoring;
- Services related to precious metals and stones if connected to the Syrian government.
Asset Freezes and Resource Provision Ban
Any assets belonging to individuals or organizations on sanction lists are fully controlled and cannot be used:
- Providing financial or material resources directly or through intermediaries is prohibited;
- Assets are “frozen” and cannot be sold, transferred, or used.
Our lawyers have experience in removing entities from the Specially Designated Nationals (SDN) list and assist in preparing petitions to OFAC.
Entry Bans and Travel Sanctions
Executive Order No. 13608 prohibits entry into the U.S. of persons supporting the Syrian regime or threatening regional security. Exceptions are made for humanitarian purposes to avoid blocking necessary aid.
Protection of Syria’s Cultural Heritage
Sanctions support UN Security Council Resolution No. 2199, aimed at protecting cultural assets illegally removed from Syria. Archaeological, historical, and religious sites are safeguarded to prevent illegal trade.
Permitted Transactions: What Is Allowed?
Despite broad restrictions, exceptions permit:
- Export and import of goods not connected to sanctioned persons;
- Transfers of funds unrelated to sanctioned entities;
- Humanitarian aid and non-commercial operations.
If activities are not covered by OFAC’s general license, one can apply for individual authorization. Our specialists are ready to assist with filing such requests.