Syria Relief Regulations: What Should We expect?

On June 30, 2025, President Trump issued Executive Order 14312 as part of his effort to reduce sanctions against Syria: “The United States is committed to supporting a Syria that is stable, unified, and at peace with itself and its neighbors.” Already we have seen the result of these relief efforts in some government departments, including the Treasury Department, where General License 25 has been released authorizing transactions previously prohibited by the Syrian Sanctions Regulation and several entities have been removed from various sanctions lists such as the Specially Designated Nationals list.

            However, as of yet we have not seen the published changes to our Export Control Regimes such as the EAR (Department of Commerce/BIS) and the ITAR (Department of State). As of right now, we remain in a waiting period while presumably these regulation changes are finalized and all necessary reporting to congressional committees is completed. This pause may have led to the belief that no relevant regulation changes are forthcoming. This however, appears to be incorrect if one examines the information included in Executive Order 14312 and compares it to the already existing regulations in places like the EAR.

As of today, Syria’s status in the EAR is unchanged. They remain a D:5 country on the U.S. Arms Embargoed list. The regulations also still state "A license is required to export or reexport all items subject to the Export Administration Regulations (EAR) to Syria of other than food or medicine designated as EAR99” and there remains a general policy of denial for all licenses as stated in Section 746.9. However, the EAR regulations against Syria were issued in response to Executive Order 13338 of May 2004 and the implementation of the Syria Accountability Act. That means that we likely are not yet seeing the effect of the most recent Trump Administration Executive Order revoking Syria sanctions: Executive Order 14312. Below is some of the language from the E.O. and related acts that indicate what I believe to be upcoming changes.

"I hereby determine pursuant to section 5(b) of the Syria Accountability Act that it is in the national security interest of the United States to waive the application of subsection (a)(1), with respect to items on the Commerce Control List (supp. No. 1 to 15 C.F.R. part 774) only, and subsection (a)(2)(A) of the Syria Accountability Act only.”

Subsection (a)(1):

"The President shall prohibit the export to Syria of any item, including the issuance of a license for the export of any item, on the United States Munitions List or Commerce Control List of dual-use items in the Export Administration Regulations (15 CFR part 730 et seq.)”

Subsection (a)(2)(A):

" A) Prohibit the export of products of the United States (other than food and medicine) to Syria"

So as you can see from this section on the Syria Accountability Act, the new Executive Order is waiving the absolute prohibitions on EAR technology that ban/create a policy of denial on all exports to Syria. Below is some additional indication from the E.O. that regulation changes are forthcoming:

"(b)  The Secretary of State shall take all appropriate action to review the designation of Syria as a State Sponsor of Terrorism consistent with…section 40 of the Arms Export Control Act.”

This review could affect Syria’s status as an Arms Embargoed Country, removing the AT reason for control and freeing up many exports to the nation.

"I hereby waive the following sanctions imposed on Syria...(iii)  the restrictions on the export of national security-sensitive goods and technology under section 307(a)(5) of the CBW Act and on all other goods and technology under section 307(b)(2)(C) of the CBW Act"

This waiver provides further proof of upcoming changes and specifically targets national security-sensitive goods and technology, potentially lessening NS controls on products intended for Syria.

To summarize, the language in the new Executive Order clearly indicates changes to export controls surrounding Syria. As of now however, they are not implemented and we have few indications of what industries exactly will see restrictions lessoned for export controls. Therefore, we cannot definitively say what specific areas of industry will face eased export controls.

The Executive Order authorizes the various department heads to begin taking actions to implement the executive order. In some instances however, like in the case of the Syria Accountability Act, a report must be submitted to various congressional committees containing the reasons for the waiver being implemented. Since this executive order was released only at the end of June, we are likely in the period where the regulations, reports, and other considerations are currently still being drafted. As such, the regulations are not yet implemented and we cannot offer definitive guidance on what future actions should be taken, other than the usual amount of due diligence when engaging in business transactions with Syria. Until further notice of the completed implementation actions at the department levels, efforts to export goods other than food and medicine can only be accomplished via an approved Commerce license.