By doing so, Syria is no longer a Comprehensively Embargoed country, but some restrictions still apply. These regulatory changes align the OFAC and BIS regulations with the June 30, 2025 Executive Order "Providing for the Revocation of Syria Sanctions."
Division of Research
Syria No Longer Comprehensively Embargoed
The Department of the Treasury's Office of Foreign Assets Control (OFAC) is amending the Syrian Sanctions Regulations to remove them from the Code of Federal Regulations, consistent with Executive Order 14312 of June 30, 2025, “Providing for the Revocation of Syria Sanctions.”
In this final rule, the Bureau of Industry and Security (BIS) makes changes to the Syria export control measures under the Export Administration Regulations (EAR), consistent with Executive Order (E.O.) 14312, Providing for the Revocation of Syria Sanctions, which directed the removal of sanctions on Syria.
Syria no longer comprehensively embargoed, but still listed in country groups D3, D4 and D5
Countries listed in groups D3, D4 and/or D5 have significant export restrictions. BIS created license exceptions that will allow the export of certain EAR99 items to Syria. However, this does not mean that all activities in Syria are now allowable.
Guidance for considering activities with, or research in, Syria
- Restricted party screening remains critical. Removing the sanctions also removed the basis for many businesses and individuals being placed on restricted party lists, but many others remain on lists—particularly those who had high level positions within the Assad regime or were associated with human rights abuses, terrorism/terror financing, or other problematic activities.
- Syria remains a high-risk destination for institutional travel. Removal of the U.S. sanctions does not eliminate the physical and other risks present for travelers to/in Syria. Institutional travel to Syria requires a Safety Plan (more information on high risk international travel) which will include the appropriate mitigation measures.
- Many physical exports to Syria remain restricted. As a reminder, Environmental Health and Safety manages research shipments. The Export Control team will apply for an export license if required.
- Many vendors will need to update their contract terms or make other changes to facilitate use of their products or services in Syria—and they will do so on their own timeline to align with their own risk tolerances. We are continuing to monitor this where a company has published their restrictions or terms online: as of this morning, Zoom has not made changes to their restrictions on using their products & services in Syria.
- The wholesale removal of the sanctions should mean that banks will be more receptive to processing payments to/from Syria but it is still up to their own risk tolerances and any other laws/regulations that may limit their activities.
All activities with or in Syria require advance coordination with Export Control. Contact exportcontrol@brown.edu to request assistance.