Impact of Syrian Sanctions on Businesses and the Importance of Anti-Money Laundering Compliance
In a notable development, US sanctions on Syria have been eased significantly as of mid-2025, following the revocation of many restrictions under the June 30, 2025 Executive Order titled “Providing for the Revocation of Syria Sanctions.” This rollback removes sanctions on many entities but maintains them on Bashar al-Assad, associates, specific individuals involved in human rights abuses, chemical weapons activities, ISIS affiliates, and Iranian proxies.
The easing is intended to support Syria’s reconstruction and humanitarian efforts, particularly in facilitating electricity, energy, water, and sanitation projects. These waivers are temporary and contingent on the interim government’s compliance with US policy priorities, including human rights.
However, foreign companies still face significant trade restrictions due to remaining sanctions on regime-linked individuals and export controls, primarily from the US. Some sanctions are waived for humanitarian and reconstruction purposes, but full sanctions removal has not occurred. No broad exemptions for countries other than these waivers are officially recognized.
The Caesar Act sanctions remain but are temporarily waived; full export controls and restrictions on dealings with sanctioned entities continue to apply. Secondary sanctions and Syria’s designation as a State Sponsor of Terrorism are under reconsideration but not fully revoked.
Syrian businesses can still trade with companies from India, China, and Russia, as long as they stay compliant with regulatory laws and avoid using anything American. However, doing business with Syria is considered high risk due to its association with money laundering and its presence in various AML blocklists. Transactions with Syria cannot be carried out in US dollars. Trading between US-based companies and Syria is prohibited. Any investments by US and EU persons in the Syrian economy are also prohibited.
The European Union has imposed a special ban, prohibiting the export and sale of luxury goods in Syria or to the Syrian population. The sale and import of Syrian cultural property, as well as assistance in their restoration, are also prohibited by the European Union.
The US Treasury gave JPMorgan Chase a $5.3 million fine for conducting transactions related to Syria and servicing the accounts of individuals under sanctions. European and American companies can be fined $500,000 or more per transaction for sanctions violation. A rare company will volunteer to get involved with Syrian businesses due to the fear of noncompliance with AML regulations, leading to huge governmental fines and reputational damage.
Russian company "Sovracht" was charged with the violation of sanctions by the US Department of Justice for delivering jet fuel and transferring money to Syria in dollars through American financial services. Ignorance of the US restrictions on Syria can lead to sanctions fines, as demonstrated by the case of Russian company "Sovracht".
Companies can make transactions only in Syria's national currency through banks in Syria, Lebanon, and the UAE, resulting in a 10-15% loss of profit on cross-border transactions. American individuals are prohibited from financing or facilitating any foreign transactions subject to sanctions. American software, websites like GitHub, Adobe Flash, Yahoo email, and Coursera are unavailable in Syria, and Apple products are unavailable for sale.
American banks, Visa, and Mastercard payment systems are not functioning in Syria. These sanctions significantly impact Syria's economy by making business transactions extremely difficult and limited. The up-to-date information on sanctions against Syria can be found on the websites of the U.S. Department of the Treasury and EU agencies.
[1] The Washington Post. (2025, June 30). US eases sanctions on Syria, revoking many restrictions under June 30 executive order. [online] Available at: https://www.washingtonpost.com/world/2025/06/30/us-eases-sanctions-syria-revoking-many-restrictions-under-june-30-executive-order/
[2] Reuters. (2025, June 30). US eases sanctions on Syria, but some remain for regime figures and entities linked to terrorism or human rights abuses. [online] Available at: https://www.reuters.com/world/us-eases-sanctions-syria-but-some-remain-regime-figures-and-entities-linked-terrorism-2025-06-30/
[4] Council on Foreign Relations. (2025, July 1). US Sanctions on Syria: What's Changed and What's Next? [online] Available at: https://www.cfr.org/blog/us-sanctions-syria-whats-changed-and-whats-next
- Despite the easing of US sanctions on Syria, foreign companies are still confronted with significant trade restrictions, particularly due to remaining sanctions on regime-linked individuals and export controls.
- In the realm of finance, American individuals are prohibited from facilitating any foreign transactions subject to sanctions, and American software, websites, and Apple products are unavailable in Syria.
- In the domain of lifestyle, luxury goods export and sale to Syria or the Syrian population are banned by the European Union, and Syrian cultural property restoration assistance is also prohibited.
