EU Lifts Most Economic Sanctions on Syria

European Comm ission Frequently A sked Quest ions – EU sanction s concerning S yria November 2025 upd ate 1. Which sanction s were lifted on 28 May 202 5? What has changed? On 28 May 2025, the EU lifted almos t all sectoral econom ic sanctions on Syria. Most s ignificantly, this includes the lifting of sanct ions concerning banki ng and finance, energy, transport, and certain import and expo rt restrictions. The decision ai ms at support ing a peaceful transition in Syria fo llowing the fa ll of the Al -Assad regime in December 2024 a nd facilitating S yria’s econo mic recovery. 2. What does it mean that sanctio ns are ‘lifted’? The EU’s decision t o lift several s anctions means th at those restrict ions are no lo nger in force and do not apply. EU oper ators are free to engage in th ose activities w ithout rest riction as this would be in compliance with EU sanctions as of 28 May 2025. 3. Which sanction s have been main tained? The EU’s decision t o imple ment a broad lif ting of sanctions on Sy ria is pa rt of its support for a peace ful transition. In line w ith this, the EU has decid ed to maintain a smal l number of r estrictions. Restrictio ns maintained are: - A prohibition on t he supply of arms to Syria - Restrictions on th e export to Syri a of items that could be use d for internal repres sion - Restrictions on th e import from /export to Syr ia of items tha t could be used for telecommunica tions monitorin g or intercept ion - Restrictions on th e import f rom/export to Syr ia of cultural heritage items - Listings of indivi duals and entities linked to the Al - Assad regime. 4. What has happened to the list ings of individua ls and entities? The broad lift ing of sanctio ns has involved th e delisting of 29 entities. Several of these entities a re banks, including the Cent ral Bank of Syr ia, and comp anies operating i n key sectors fo r Syria’s econo mic recovery such as o il production and refining, cot ton production, tel ecommunicat ions, and medi a. In practice this means that these individuals and entities are no longer subje ct to an asset freeze, and it is no longer prohibi ted to mak e funds or econom ic resources a vailable to the m. The EU has ma intained the listings of individuals and entities l inked to th e Assad regime, inc l uding leading businesspersons operating in Syria linked to t he former al-Assad regime, mem bers of the Al- A ssad or Makhlo uf famili es, or Syrian Gover nment Minister s in power between May 2 011 and December 2024. 5. What does the liftin g of sanctions mean for banking rel ationship s between EU and Syrian banks? Financial and bank i ng channels ar e essential for engagement wi t h the Syrian e conomy. It is now possib le for an EU financia l or credi t i nstitution t o open a new ban k account in Syri a, to establish correspondent bank ing relationships with Sy r ian financial inst itutions, to open a new represen t ative office or branch in Syria, or to establish a new join t venture with Syrian financ i al institutions.

1. I need to make o r receive a payment to/fro m Syria. Is t his permit t ed? Yes. Payments to or from Syria are genera l ly permi tt ed. EU sanctions do not p rohibit EU banks from processing t r ansaction s t o or from Syr i a or fro m transacting with S yrian banks. Payments are only prohibited if: • they benefit, d irectly or indirect l y, natural or l egal persons who a re subject to restrictive measures; or • they are made to or via Syri an ba nking and fina ncial institutions subject t o restric t ive measures restrictions; or • they relate to good s or services whose import or export is restricted und er the EU’s sanctions concerning Syria. Operators must st i ll comply wit h obligation s stemming from Anti Money L aundering and Counter- Financing Terror ism rules. 7. Are Internationa l Financi ng Institutions allowed to finan ce projects in Syria? Yes, according to the applicable conditions. International Financ ing Institutions (‘IFI s’) that are constitu t ed under EU tr eaties, such as the Europ ean Investment Bank (‘EIB’), or that implement EU p rojects in line with EU budget r ules (e.g., the European Bank for Reconst r uction and D evelopment (‘EBRD ’) are bound by EU sanctio ns. Those IFIs are permitted to finan ce projects in areas not prohi bited by EU sanctions. The r e is no prohibition on the financing of pr ojects in Syria by such IFIs. Howeve r, when financ i ng projects in Syri a, IFIs must ensure that EU fund s are not channeled, direc t ly or indirectly, t o listed indiv iduals or entities, unless exceptions apply. 8. Is the humanit arian exemption from asse t freeze measure s and the prohibition on mak i ng funds or econom i c resources av ailable to list ed persons, in troduced after the 2023 earthquake, still i n force? The EU has reta i ned this exe mption and has removed any expiry date apply ing to it. Following t he February 2023 e arthquake, the Coun cil adopted a humanitarian exemption to facilitate the spee dy delivery of humanitarian a ssistance. This exemption wa i ved the nee d for the spec ific categories of humanita r ian operators to seek p ri or per mission from NCAs to p r ovide fund s or econom ic resources inte nded for humanitarian purp oses to listed persons and entit i es. 9. I am a humanitari an, development or other econo mic actor active in Syria. H ow can I reassure banks and supp liers that my activities ar e not subject to EU sanctions? The EU’s decision t o lift sanctions and introduce exemptions from se veral sanctions on Syria has changed the landscape for t he banking sector when engag i ng with Syria, mak ing possible a wide range of transactions. Opera t ors sho ul d be ready to suppo rt the banks in pro cessing related transact i ons. When initiating a trans ac tion for n on -prohibited act ivity in Syria, ope rators are encouraged to share all re levant information with bank s and other private actor s, including legal r eferenc es of the applicable EU sanctions and except ions. For human itarian and devel opm ent actors, t his might al so i nclude co m fort letters that a donor may have granted them, the i r risk as se ssment of the ac tion and the mitigating measures, and pos si ble certif i cations they may have been awarded.

2. Who can I ask if I have doubts on whether my act ivities, as a hu m anitarian, devel opment or other economic ac tor, would be subject to EU sanctions? Sanctions imp lementation a nd enforcement is the respo nsi bility of the Member States. When doubts arise, the Member Stat e National Competent Auth ority (‘the NCA’) should b e c ontacted. The NCAs of each Member St at e are iden t ified on the web sites listed i n Annex II I of Council Regulation (EU) No 36/2012 concerning restrictive measures in view of the situat ion in Syria (‘ Syria Regulat i on’). Opera t ors must address the NC A with which they have the closest link. 11. What is the inte rpl ay between EU sanctions and US sanct i ons in relati on to Syria? Am I subject to US sanc t ions if I am a humanitarian, development or other econo m ic actor ba sed in the EU? Operators under t he jurisdi ction of a Member S tate or carrying ou t operations in the EU are only requi red to comply with EU sa nctions. Compliance with US sa nctions is there fore discretiona ry upon them. US sanctions might b e i ntende d t o produce e f fects beyond the US t erritory and see k to regulate the behaviour of EU economic o perators that have no signi f icant connect i on to the US. How ever, the EU does not recognise the ex t ra-territorial ap plication of laws adopted by third countri es and considers suc h application to be c ontrary to international law. 12. Are financial tran sactions carried out th rough specialised mes saging banking services, such as the SWIFT ne twork, allowed? Yes. There are no restrictions on t he use of speci alised financial messaging se r vices in t he EU’s sanctions conce r ning Syria. This mea ns incorporated u nder the law o f a MS, such as ca n pr ovide specialised financi al messaging s er vices and opera t ors can make bank transa ctions with Syri an banks using SWIFT code s. 13. Is the export from the EU to Syr ia of general industria l machinery, re lated co mponents and related technica l services all owed? Yes. The export o f general indus t ry machine r y, related components, spare parts an d related technic al services is perm itted, provided th at they are no t goods listed in Annexes Ia, V or IX of Regulation 36 / 2012 and that they a re not dual-use goods. 14. Are EU operators allowed to purchase or impo rt handcraft, agricultural, f orestry and fishing products f rom Syria? Yes. There are no r estrictio ns on the purchase or impor t into the EU o f the above-mentioned goods fro m Syria. There are no r estricti ons on the supply of transport and f i nancial ser vi ces related t o t hose goods, provided that the goo ds are not purchased from i ndividuals or entities sub ject to individual restrictive measures. 15. What abou t contracts between EU operators an d Syrian operato rs whose performanc e became prohibited w hen sanctions v i s-à-vis Syria came into for ce in 2012 and thereafter? Sanctions pre vail over co ntractual agreem ents. Hence, contracts between EU and Syrian operators that were at odds with supervening sanctions could not and should not be performed. EU operato rs were shielded from legal consequence for non-perform ance of such contracts under Article 27 of Council Regulation 36/2012.

However, the impositio n of sanction s does not mean that the contrac t rendered non-performab l e due sanctions restr ictions is te r minated. It is f or the par t ies to se t tle, whenev er possible, the ir contractu al situation. Where this was not possible, and dependin g on the circumstances, contracts could effectively be suspended by the parties, if a sanctions measure ma de the performanc e of the contr act ual action pro hi bited. In this vein, now th at restrictions are lifted, the contracts might simply be resumed by the parties, if that is allowed pursuant t o the app l icable law of t he contract. Claims brought forward by persons indicated in Artic l e 27 (1)(a) -(c) of Council Regulation 36/2012 must not be upheld, in cluding by Membe r State courts, if they are raised in connection with any contrac t or transaction the performance of whi ch has been affect ed while the relevant res triction was in force. In other words, a Syrian person or entity, or designat ed persons, entities or bodies listed in Annex II, IIa or IIb, or persons, en tities or bodies that were lis t ed i n Annex II, IIa or IIb prior t o 28 May 2025, c annot claim damages after 28 May 2025 from an operator in a Member State for non-performance of an action which was restricted bef or e that date, eve n if the cl aim is brought forward a f ter 28 May 2025.