The U.S. Departments of Commerce and the Treasury took steps this September to further ease restrictions on Syria following the fall of the Assad regime. In early September, the Commerce Department’s Bureau of Industry and Security (BIS) revised the Export Administration Regulations (EAR) to relax certain export controls on Syria. On September 25, the Treasury Department’s Office of Foreign Assets Control (OFAC) renamed the “Syria-Related Sanctions Regulations” the “Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations,” further clarifying the scope of the Syria-related sanctions that have been lifted and the focus of those that remain.

These measures further implement the Trump administration’s landmark announcement that it would ease restrictions on business in Syria to support critical economic and stabilization efforts and promote peace, economic security, and prosperity in the region. Of particular note, the relaxation of export controls under the EAR has significantly expanded opportunities for exports of commercial and certain other goods to Syria.  

BIS Relaxes Certain Controls on Exports to Syria

On September 2, 2025, BIS made several changes to the EAR to relax export controls on Syria. While the administration largely lifted economic sanctions on Syria this summer, the country remained subject to extensive export controls under the EAR, generally prohibiting exports of even basic commodities to the country without a license from the U.S. Government, with limited exceptions.

In its final rule this September, BIS created a new license exception for exports to Syria of less-sensitive commodities, expanded the availability of certain license exceptions for exports to Syria, and established a more favorable licensing policy for exports to Syria.

License Exception Syria Peace and Prosperity (SPP) (15 C.F.R. § 740.19)

Of greatest significance, BIS established a broad new license exception, License Exception Syria Peace and Prosperity (SPP), authorizing exports of non-dual use items to Syria without a license.

BIS maintains a list of sensitive commodities, software, and technology warranting heightened export controls, called the Commerce Control List (CCL). Goods that are not identified on the CCL are designated as EAR99 and are only subject to control in certain limited circumstances, such as for export to embargoed countries.

While BIS did not lift the broad export controls on Syria, License Exception SPP now authorizes exports and reexports of EAR99 items to Syria without an export license (unless otherwise prohibited). The exception significantly reduces the restrictions applicable to most U.S.-origin goods, from concrete to automobiles, and creates new opportunities for exporters to the Syrian market and for the people seeking to rebuild their country.   

Exporters do, however, need to continue to be mindful of other restrictions that could apply, including if restricted parties (e.g., Entity List entities) or prohibited end-uses are involved.    

Expanding Application of Existing License Exceptions

BIS additionally expanded the applicability of several existing license exceptions for exports and reexports to Syria. These include the following license exceptions:

• Consumer Communications Devices (CCD) (15 C.F.R. § 740.19), authorizing exports of certain common electronics items identified on the CCL.
• Aircraft, Vessels and Spacecraft (AVS) (15 C.F.R. § 740.15), authorizing, in certain circumstances, temporary sojourn of civil aircraft and vessels to Syria and exports to Syria of vessel, aircraft, and ship and plane stores.
• Temporary Imports, Exports, Reexports, and Transfers (in-country) (TMP) (15 C.F.R. § 740.9), authorizing, among other things, technology exports accessed through secure connection, exports of specified containers, exports to owned or controlled affiliates or facilities in certain circumstances, and protective gear exports to U.S. persons affiliated with the U.S. Government.
• Servicing and Replacement of Parts and Equipment (RPL) (15 C.F.R. § 740.10), authorizing exports of one-for-one replacement parts, components, accessories, and attachments for previously exported equipment.
• Governments, international organizations, international inspections under the Chemical Weapons Convention, and the International Space Station (GOV) (15 C.F.R. § 740.11), authorizing selected exports to certain U.S. partners and to the Organization for the Prohibition of Chemical Weapons for international inspection and verification uses.
• Technology and Software – Unrestricted (TSU) (15 C.F.R. § 740.13), authorizing, among other things, export of copies of technology previously authorized for export to the same recipient.

Reliance on these exceptions for exports or reexports to Syria requires careful assessment of their conditions and any end-use or end-user restrictions.  

Licensing Policy

Finally, BIS implemented more permissive licensing policies for exports to Syria by establishing a presumption of approval for exports of certain items identified on the CCL for commercial end-uses supporting the economic and business development of Syria and its people. Such commercial end-uses include improvements or maintenance of telecommunications, water supply and sanitation, power generation, aviation, and other civil services when they do not significantly contribute to Syria’s military potential or ability to support acts of international terrorism.  

Clarifying Key Remaining Sanctions Related to Syria

Separately, on September 25, OFAC issued a final rule changing the heading of the “Syria-Related Sanctions Regulations,” set forth at 31 C.F.R. Part 569, and implementing in the Code of Federal Regulations the current scope of certain Syria-related sanctions that remain in place following the administration’s general termination of the Syria sanctions regime.

This summer, through Executive Order 14312 (June 30, 2025), the administration lifted most U.S. sanctions on Syria as a response to developments surrounding the fall of the Assad regime. It was a sea change moment for one of the most comprehensively sanctioned countries in the world. However, the administration did maintain certain Syria-related restrictions, particularly targeting collaborators of the former regime, terrorist organizations, war criminals and human rights abusers, weapons of mass destruction users and proliferators, narcotics traffickers, and others threatening peace, security and stability in Syria and the region. As a result, certain Syria-related sanctions have continued, creating certain ambiguity about the status of the Syria sanctions program and the residual sanctions risks for transactions involving Syria.

In its September final rule, OFAC incorporated the current scope of a number of continuing Syria-related sanctions within the Code of Federal Regulations, set forth at 31 C.F.R. Part 569, and changed their name from the “Syria-Related Sanctions Regulations” to the “Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations.” The revisions should help to clarify certain Syria-specific sanctions that remain in place for businesses and organizations seeking new opportunities in Syria.        

Looking Ahead

While certain sanctions and export controls remain, the administration continues to take steps to provide relief for Syria and its people, and more opportunities may continue to arise as the processes initiated with Executive Order 14312, including the State Department’s review of Syria’s designation as a State Sponsor of Terrorism, continue to proceed. Miles & Stockbridge’s international trade lawyers will continue to monitor developments related to Syria and can advise on what the recent changes mean for businesses.

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