Syria’s Sanctions Thicket

On January 31, 2025, the Congressional Study Group on Foreign Relations and National Security convened virtually to discuss the complex sanctions landscape in Syria following the collapse of the Assad regime in December 2024. 

The sudden, unexpected collapse of the Assad regime in Syria late last year created a glimmer of hope for economic and political recovery in that country for the first time in almost two decades. But efforts to reengage with Syria are inevitably complicated by the dense thicket of international and bilateral sanctions that continue to apply to various parts of and actors within Syria. This includes sanctions on the group Hay’at Tahrir al-Sham (HTS) that led the effort to displace the Assad regime and has played a lead role in post-Assad government formation efforts, as it remains a designated Foreign Terrorist Organization (FTO) and Specially Designated Global Terrorist (SDGT).

For the first part of the session, study group coordinator Scott R. Anderson moderated a discussion with three leading outside experts:

• Rana Shabb, associate director for the Middle East in Conflict Resolution Program at the Carter Center;
• Delaney Simon, a senior analyst at the International Crisis Group focusing on sanctions issues; and
• Alex Zerden, the principal of Capital Peak Strategies LLC, adjunct senior fellow at the Center for a New American Security, and a veteran of the National Economic Council and U.S. Treasury Department.

Prior to the discussion, the study group circulated the following background readings:

• “S. and European Sanctions on Syria,” The Carter Center (Sept. 2020);
• Scott R. Anderson and Alex Zerden, “Our Man in Damascus? Sanctions and Governance in Post-Assad Syria,” Lawfare (Dec. 13, 2024);
• Delaney Simon et al., “Don’t Repeat in Syria the Mistakes of Afghanistan,” Foreign Affairs (Jan. 2, 2025); and
• Delaney Simon, “S. Sanctions Relief for Syria is an Important Start, but Not Enough,” Lawfare (Jan. 23, 2025).

Simon opened the discussion by outlining the extensive network of overlapping U.S., E.U., and U.N. sanctions on Syria. Among other restrictions, the U.S. State Sponsor of Terrorism (SST) designation, imposed on Syria since 1979, restricts U.S. arms sales, financial assistance, and engagement with multilateral development institutions;  comprehensive economic sanctions prohibit trade, investment, and financial transactions involving many Syrian entities; sectoral sanctions target Syria’s energy, banking, and telecommunications industries; and HTS-specific sanctions complicate engagement with Syria’s new governing authorities.

Simon emphasized that, while many of these sanctions were originally designed to pressure Assad’s regime, they now pose obstacles to post-Assad reconstruction and humanitarian relief. She warned that a failure to reassess these restrictions could lead to prolonged economic devastation and political instability in Syria.

Zerden then provided an in-depth review of U.S. sanctions, highlighting their complexity and long-standing impact on Syria. He noted that sanctions have been layered over multiple decades through various legislative acts, executive orders, and regulatory measures, creating what he described as a “Gordian knot” of restrictions. These included: the Caesar Syria Civilian Protection Act (2019), which imposes penalties on entities engaging in significant transactions with the Syrian government; the Iran Threat Reduction and Syria Human Rights Act (2012), which tightens restrictions on financial transactions involving Syria; and at least eight executive orders targeting Syria for issues ranging from human rights abuses to chemical weapons use and regional destabilization. Zerden stressed that while these sanctions helped weaken the Assad regime, their continued enforcement may undermine efforts to stabilize Syria’s new government. He suggested a need for a fundamental reevaluation of their “fit for purpose” status in the current context.

Shabb then shifted the discussion to the real-world effects of sanctions on Syria’s economic and humanitarian conditions. She highlighted several key challenges arising from the current sanctions system, including:

• Severe energy shortages, with major cities like Damascus receiving only one hour of electricity for every ten hours;
• Financial isolation, with Syria’s banking sector cut off from international markets, forcing reliance on informal money transfer systems;
• Obstacles to reconstruction, as foreign companies and investors hesitate to engage due to sanctions-related risks.

Shabb also raised concerns about the absence of economic incentives for Syria’s transitional authorities. Without tangible “peace dividends,” she warned that HTS and other governing actors might struggle to maintain stability, increasing the risk of renewed conflict or extremist resurgence. She also emphasized the importance of regional engagement, particularly from key stakeholders like Saudi Arabia and Jordan, whose investments could be crucial for Syria’s recovery.

The discussion then turned to General License 24, issued by the U.S. Treasury Department in early January 2025. Simon explained that this six-month license was intended to provide substantial sanctions relief by authorizing transactions relating to essential services and governance functions in Syria, permitting certain energy-related business transactions, and facilitating limited remittances through the Syrian Central Bank.

While Simon praised the issuance of the license as an important first step, she pointed out several shortcomings. First, it did not lift core sectoral sanctions, meaning Syria’s economy remained largely restricted. She also described the six-month duration of the license as too short, as it would discourage meaningful long-term investments or aid efforts. The license does not address HTS’s FTO designation, which continues to deter humanitarian and commercial engagement through the threat of criminal prosecution for material support for terrorism that accompanies FTO status. And the license fails to override export controls, meaning key supplies such as heavy machinery still require case-by-case licensing.

Simon warned that, despite the license, Syria remains subject to an effective “total embargo,” and broader reforms were necessary for meaningful economic recovery. The panelists then proceeded to discuss several potential policy paths forward, including:

• Reevaluating Syria’s State Sponsor of Terrorism designation to assess whether it remains appropriate given the changed political landscape;
• Expanding the scope of sanctions relief beyond General License 24, with an emphasis on long-term economic stabilization;
• Clarifying sanctions exemptions for humanitarian aid and reconstruction efforts to reduce compliance burdens on NGOs and businesses; and
• Engaging regional partners to facilitate investment and economic integration in post-Assad Syria.

In all, the discussion underscored that while sanctions were originally designed to target Assad’s regime, their persistence now hinders Syria’s transition and stability. Participants emphasized the need for a careful reassessment of these measures to ensure they align with U.S. foreign policy goals in the post-Assad era.

The study group then concluded with an open discussion session, during which attendees were free to comment on and pose questions regarding the various issues raised.

Visit the Congressional Study Group on Foreign Relations and National Security landing page to access notes and information on other sessions.