The US has operated a sanctions programme targeting the Syrian government since 2004, focused on its association with the financing of terrorism and its historical occupation of Lebanon. Sanctions against the Syrian government and a wide ranging trade embargo were imposed by the EU and SECO in 2012, in response to human rights abuses committed by the government of Bashar Al Assad during the country’s civil war.
On 28th May 2024, the EU extended its Syrian sanctions regime until 1st June 2025.
Sanction Name
Restrictive Measures In View Of The Situation In Syria
First Imposed
Last updated
Targets
Asset Freeze, Arms Embargo, Trade Restrictions and Travel Ban:
• Syrian President Bashar Al Assad and officials in his government implicated in human rights abuses committed during the country’s civil war. The programme includes wide ranging restrictions on trade with Syria, including an embargo on the export to the country of arms, telecommunications monitoring and interception equipment, jet fuel, equipment for the oil and natural gas sector, gold, precious metals, diamonds, banknotes or coins or luxury goods. There are also prohibitions on investment in the oil and gas sector or in electricity production, trading in Syrian financial instruments, co-operation with Syrian banks, providing insurance or reinsurance services or trading in Syrian cultural goods. The importation of Syrian crude oil and petroleum products or the provision of financial services to the government of Syria is banned, with the sole exception of its use for humanitarian purposes. There are also restrictions on access to airports in the EU for certain flights.
Exemptions
1. The purchase of oil and petroleum products and the related provision of financing or financial assistance in Syria for the sole purpose of providing humanitarian relief or assistance to the Syrian civil population is authorised.
2. Exemptions can also be granted on a case-by-case basis on humanitarian grounds or to support the attendance of inter-governmental meetings.
3. Exemptions can be granted on activities and transactions necessary to facilitate humanitarian assistance in relation to earthquake relief efforts in Syria and Turkey.
Sanction Name
Restrictive Measures Related To Assassination Of Prime Minister Rafiq Hariri
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze:
• Individuals – including both Lebanese and Syrian nationals – suspected of involvement in the assassination of Prime Minister Rafiq Hariri.
Exemptions
1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or to support the attendance of inter-governmental meetings, as well as for basic expenses, the provision of legal and professional services and fees for the holding of frozen funds.
On 13th September 2024, the Swiss Federal Council indefinitely extended the temporary humanitarian exemption introduced after the February 2023 earthquake in Syria.
Sanction Name
Order establishing measures against Syria
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze, Arms Embargo and Trade Restrictions:
• Officials and associates of the Syrian government or any Syrian national deemed to be responsible for the violent repression of the civilian population. The programme includes a ban on the export to Syria of arms or related materiel, or the provision of related financial or technical services, the importation of Syrian petroleum products or the financing of such trade, support for the mining or refining of Syrian crude oil or the supply of equipment or technology for such purposes, the provision of aviation fuel, support for the construction of new power plants, the provision of equipment or technology for monitoring services, the provision of banknotes, coins, diamonds or precious metals, trading in cultural goods or the provision of insurance, reinsurance or other financial services.
• SECO prohibits all Swiss airports from accepting flights operated by Syrian Arab Airlines and all freight flights operated by Syrian transport companies, with the exception of mixed-passenger freight flights and humanitarian flights.
Exemptions
1. With the authorisation of SECO, restrictions can be lifted for goods, services, oil and petroleum products intended solely for humanitarian purposes, as well as for use by non-Syrian civil aircraft or by Syrian airlines for evacuations.
2. Arms supplied for use by the UN and non-lethal equipment intended solely for humanitarian or protective use are exempt from sanctions, as are hunting and sporting weapons.
3. Asset freeze exemptions can be granted to prevent cases of rigor; in respect of existing contracts; to respect credits due under existing judicial, administrative or arbitral judgments; to provide humanitarian aid; to protect Swiss interests; to financially support Syrian citizens at university or receiving professional training in Switzerland; to destroy chemical weapons and related facilities; or for Syrian diplomatic missions and consular posts.
4. Travel ban exemptions may be granted on humanitarian grounds, to attend international conferences, to participate in political dialogue concerning Syria or if the protection of Swiss interests requires it.
5. Exemptions from certain financial transactions may be granted if these are necessary for the provision of humanitarian aid or for the support of the civilian Syrian population by public authorities and other organisations. Financial transactions necessary for diplomatic and consular missions in Syria are also exempt.
6. Exemptions were granted for the six months following the earthquake on 6th February 2023 to facilitate humanitarian assistance.
On 11th September 2024, OFAC issued an advisory note to alert persons globally to the significant U.S. sanctions risks for parties involved in petroleum shipments to the Government of Syria.
On16th October 2024, OFAC designated three individuals involved in the illegal production and trafficking of Captagon that has benefitted Bashar al-Assad’s regime and its allies, including Hizballah. The illegal trade in Captagon, a dangerous, highly addictive amphetamine, has become a billion-dollar illicit enterprise operated by senior members of the Syrian regime.
Sanction Name
Syria Sanctions Program
SANCTIONS
First Imposed
Last updated
Targets
Specially Designated National and Trade Restrictions:
• The Government of Syria and entities under its control. The programme also includes a complete prohibition on new investment in the country by US entities, a ban on the direct or indirect export of goods or services to Syria and on the importation into the US of petroleum or petroleum products of Syrian origin. There is also a ban on the financing or facilitation of such activities by third parties.
Exemptions
1. Certain transactions that support the publishing and marketing of manuscripts, books, journals and newspapers in paper and electronic format are authorised.
2. Certain activities in response to the Covid-19 pandemic.
3. Activities in certain economic sectors in non-regime held areas of Northeast and Northwest Syria.
4. Until 8th August 2023 all transactions related to earthquake relief that would otherwise be prohibited under the Syrian Sanctions Regulations
Links 1
Sanction Name
Restrictions on the Turkish government in view of the Situation in Syria
SANCTIONS
First Imposed
Last updated
Targets
Specially Designated National:
• Persons deemed to be responsible for or engaged or complicit in policies that threaten peace and stability in Syria or those ordering human rights abuses. Current or former officials of the Government of Turkey, including those who are deemed to work on or behalf of persons who are targeted by sanctions. Persons working in specific sectors in Turkey as determined by the Secretary of the Treasury. • Persons engaged in or financing the obstruction or prevention of a ceasefire in northern Syria. Persons involved in the intimidation of persons returning to their place of residence or forced repatriation of refugees to Syria. The sanction also targets those engaged in blocking UN-led political solutions to the crisis. Family members of these targets may also be sanctioned and anyone engaged in expropriation of property in Syria.
Exemptions
1. All actions committed by US government employees or contractors conducting official US Government business.
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On 8th February 2024 OFSI extended the Syrian General Licence related to humanitarian exemptions until 14th February 2025.
Sanction Name
Restrictive Measures In View Of The Situation In Syria
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze, Arms Embargo, Trade Restrictions and Travel Ban:
• Syrian President Bashar Al Assad and officials in his government implicated in human rights abuses committed during the country’s ongoing civil war. The programme includes wide ranging restrictions on trade with Syria, including an embargo on the export to Syria of arms, telecommunications monitoring and interception equipment, jet fuel, equipment for the oil and natural gas sector, gold, precious metals, diamonds, banknotes or coins, luxury goods, investment in the oil and gas sector or in electricity production, trading in Syrian financial instruments, co-operation with Syrian banks, providing insurance or reinsurance services or trading in Syrian cultural goods. There is also a ban on the importation of Syrian crude oil and petroleum products or the provision of financial services to the government of Syria, with the sole exception of its use for humanitarian purposes. There are also restrictions on access to airports in the EU for certain flights.
Exemptions
1. The purchase of oil and petroleum products and the related provision of financing or financial assistance in Syria for the sole purpose of providing humanitarian relief or assistance to the Syrian civil population is authorised.
2. Exemptions can also be granted on a case-by-case basis on humanitarian grounds or for the attendance of inter-governmental meetings.
3. Activities and transactions necessary to facilitate humanitarian assistance in relation to earthquake relief efforts in Syria and Turkey.
4. Exceptions related to petroleum products have been extended to include the UN; international and humanitarian organisations; and NGOs. Previously the exception only extended to those funded by the UK government. The amendment requires a person relying on the exception to notify the Treasury rather than the SoS and widens the scope of the exception to apply to the “acquisition”, supply and delivery of petroleum products, as opposed to their “purchase”, supply and delivery; and
amends the record keeping requirements with respect to trade licences.
