“This decision is simply the right thing to do, at this historic time, for the EU to genuinely support Syria’s recovery and a political transition that fulfils the aspirations of all Syrians. The EU has stood with the Syrian people throughout the last 14 years, and it will continue to do so. Today the EU reaffirms its commitment as a partner for the transition, one that helps the Syrian people to reunite and rebuild a new, inclusive, peaceful Syria.”

Kaja Kallas, High Representative for Foreign Affairs and Security Policy and President of the Foreign Affairs Council

These measures were adopted through:

• 2 Common Foreign and Security Policy (“CFSP”) decisions;
• 1 Council Implementing Decision; 
• 1 Council Regulation; and
• 2 Council Implementing Regulations.

The Council amended Council Regulation (EU) No 36/2012 of 18 January 2012 concerning restrictive measures in view of the situation in Syria and repealing Regulation (EU) No 442/2011 (“Regulation 36/2012”) and imposed targeted sanctions under Council Regulation (EU) 2020/1998 of 7 December 2020 concerning restrictive measures against serious human rights violations and abuses (“EU Global Human Rights Sanctions Regime”). This Insight discusses the measures that were lifted and highlight those that remain in place. 

Takeaways

• The Council’s sweeping changes to the EU Syria sanctions regime provide significant financial sanctions relief including lifting asset freeze measures targeting the Syrian Central Bank along with entities operating in the financial, petrochemical, cotton and telecommunications sectors, among others. Key trade sanctions were also lifted including on sectors such as financial services, energy, aviation, and luxury, among others. 
• At the same time, the sanctions relief for Syria was not absolute; (i) targeted financial sanctions remain imposed on individuals and companies related to the Assad regime (300+ listings); (ii) new listings were imposed under the EU Global Human Rights Sanctions Regime; and (iii) trade restrictions on equipment, technology and software that could contribute to internal repression remain (see in particular provisions regarding Annex IA, Annex IX, and Annex V). The EU keeps the ability to introduce further targeted measures, such as under the EU Global Human Rights Sanctions Regime, depending on the evolution of the situation in the country.   
• Concerning exports, the EU sanctions relief for Syria does not affect the separate EU dual-use export controls regime. As discussed below, the 28 May 2025 measures may in practice lead to heightened Member State scrutiny of dual-use exports to that country moving forward. 
• EU operators are encouraged to develop trade compliance strategies before re-engaging in Syria, including, but not limited to, monitoring the situation in Syria, knowing their products, and evaluating industry exposure to geopolitical volatility while having a clear understanding of the potential export control implications, if applicable.  

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1. Individual Restrictive Measures

Removed Designations and Derogations

The following 24 entries were removed from the EU sanctions list. As of the date of this article, 361 individuals and 67 entities remain subject to EU asset freeze measures. 

• Financial Services: Central Bank of Syria, Commercial Bank of Syria, Real Estate Bank, Syrian Lebanese Commercial Bank, and Al-Aqila Company.
• Press, TV & Telecoms: General Organisation of Radio and TV, Syriatel, Cham Press TV, and Al Watan.
• Petrochemical: Syria Trading Oil Company (Sytrol), General Petroleum Corporation (GPC), Al Furat Petroleum Company, Overseas Petroleum Trading, The Baniyas Refinery Company, The Homs Refinery Company, Pangates International Corp Ltd, Deir ez-Zur Petroleum Company, Ebla Petroleum Company, Dijla Petroleum Company, Syrian Petroleum Company, and Syrian Company for Oil Transport.
• Other: Marukat Company, General Organisation of Tobacco, and Cotton Marketing Organisation.

A new derogation under Article 15a allows for the release of certain frozen funds or economic resources, or the making available of certain funds or economic resources, to the Ministry of Defence and the Ministry of Interior, for the cooperation between those entities and a Member State’s governmental entity or body in the areas of reconstruction, capacity-building, counter-terrorism and migration.

EU Global Human Rights Designations - At the same time, two individuals and three entities were added to the EU Global Human Rights Sanctions Regime following violence in the coastal region of Syria. These newly added individuals and entities are subject to asset-freezes and restricted access to funds. Natural persons are additionally subject to a travel ban.

2. Overview of Lifted Sanctions

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3. Overview of Measures Remaining in Force

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Potential Impact on EU Export of Dual-Use Items 

As a reminder, Regulation (EU) No 821/2021 (the “Dual-Use Regulation”) generally applies to the export of dual-use items to Syria. Under the Dual-Use Regulation’s “catch-all clause”, Member States may control the export of dual-use items not listed in Annex I whenever they are intended for a military end-use (as defined in Article 4(1)(b)(i)to(iii)) in a country subject to an arms embargo.  

Since EU Syria sanctions concerning arms are limited to the financing or financial assistance of Common Military List items imports and do not concern arms exports, Syria is not subject to an arms embargo. Consequently, in principle, the Dual-Use Regulation catch-all clause would not apply by itself in the case of Syria.    

However, Article 2d of Regulation 36/2012 overrides the arms embargo condition of the Dual-Use Regulation for Syria, enabling as a result Member States to trigger the dual-use catch-all clause, i.e. control the export of items not listed in Annex I of the Dual-Use Regulation when they are intended for a military end-use in Syria. Article 2d of Regulation 36/2012 also allows Member States to prohibit altogether such exports (non-Annex I items intended for a military end-use).

Conclusion 

Whilst the EU has now lifted a large majority of its restrictive measures against Syria in an effort to allow the country to rebuild its economy, certain measures remain firmly in place for security reasons. 

By adding new (legal) persons to the EU Global Human Rights Sanctions Regime, the EU is demonstrating that it continues to closely monitor the human rights situation in the country and will implement specific sanctions where necessary, using the full range of the restrictive measures toolbox as it did alongside its 17th package regarding Russia.

Companies should remain aware of the EU sanctions that remain in place. Transactions subject to export controls involving Syria will likely be subject to heightened scrutiny in Member States. All in all, EU operators should ensure they perform targeted and up-to-date EU-specific risk assessments and carefully plan and prepare for their potential return to Syria, as the country remains a high-risk jurisdiction from a compliance perspective beyond sanctions and export controls.

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