By Mattia Knecht
President Trump’s sudden move to lift sanctions on Syria has opened a window for economic and political reengagement. Yet behind the headlines lies a complex matrix of statutory barriers, international expectations, and institutional inertia. This article explores whether the momentum of executive action can overcome entrenched legal constraints and translate into a sustainable recovery for Syria.
On May 13, 2025, U.S. President Donald Trump announced his intent to lift all sanctions on Syria, stating he would “order the cessation of sanctions against Syria in order to give them a chance at greatness.” The declaration, made during a speech at the Saudi-U.S. investment forum in Riyadh, marked an unexpected reversal of longstanding U.S. policy towards the country. This announcement has prompted several U.S. allies, including the European Union, to lift economic sanctions, while others, such as Japan, are considering similar actions.
More recently, on May 23, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) issued General License 25 (GL 25), effectively authorizing transactions with Syria’s interim government, central bank, and several state-owned enterprises. Concurrently, the U.S. Department of State granted a 180-day waiver under the Caesar Syria Civilian Protection Act, suspending secondary sanctions on non-U.S. entities engaging in activities covered by GL 25 during this period. This policy shift represents a pivotal moment for Syria’s political transition as well as economic future. After several years of isolation under one of the world’s most comprehensive sanctions regimes, the prospect of renewed international engagement offers both opportunities and challenges for the country’s economic recovery and, eventually, transition in the aftermath of the Assad family rule.
Navigating the Complex Legal Landscape of U.S. Sanctions on Syria
Despite heightened expectations from the sanction relief, the actual lifting process will require close cooperation between other sanctioning entities and the Syrian authorities. Although the Trump administration has provided partial sanctions relief to the Syrian people, and in contrast with the EU, lifting U.S. sanctions is a more complex and multi-layered process involving statutory benchmarks, U.S. government inter-agency coordination and action, as well as congressional involvement.
U.S. sanctions are implemented by presidential executive orders or by legislation adopted by Congress, such as the Syrian Accountability and Lebanese Protection Act (SAA) or the Caesar Syria Civilian Protection Act, also known as the Caesar Act. While President Trump can lift presidential executive orders, lifting or repealing legislative sanctions requires congressional action. As Congress has recently renewed the Caesar Act for another five-year term, it can only be repealed until after the end of this period.
Both the SAA and the Caesar Act stipulate specific conditions for the lifting of sanctions. Although some criteria have been met following the fall of the Assad regime, others look seemingly elusive. For instance, the Caesar Act requires under Section 401:
- The release of all political prisoners and access to appropriate international human rights organizations to detention facilities.
- “The Government of Syria is permitting the safe, voluntary, and dignified return of Syrians displaced by the conflict.”
- “The Government of Syria is taking verifiable steps to establish meaningful accountability for perpetrators of war crimes in Syria and justice for victims of war crimes committed by the Assad regime, including by participation in a credible and independent truth and reconciliation process.”
Nonetheless, waiver provisions under both the SAA and the Caesar Act allow the president to suspend sanctions for renewable 180-day periods based on national interests. In addition, the OFAC has the authority to temporarily exempt sanctions provisions. This is the current administration’s intention for swift relief of the sanctions regime, as seen by the measures of May 23.
Practical Barriers to Sanctions Relief
Obstacles to effective sanctions relief extend beyond statutory conditions. As U.S. Secretary of State Marco Rubio acknowledged during a congressional hearing on May 21, 2025, the process of sanctions removal should be, in his view, “incremental.” This reflects not only legal constraints, such as the renewable 180-day waivers under the Caesar Act but also the chilling effect these temporary measures create for long-term investors. Businesses are hesitant to commit capital when the legal environment may revert within months. General licenses, for instance, can be revoked within a few hours if needed. Bureaucratic issues further compound the problem, both within U.S. institutions and among Syrian administrative bodies unaccustomed to operating within international compliance frameworks. Meanwhile, overlapping restrictions such as export controls under the SAA and Specially Designated Nationals (SDN) listings continue to deter engagement. Without harmonization of regulatory guidance and assurance mechanisms—such as escrow systems or clear compliance frameworks, international actors remain wary of reentry into the Syrian market.
Syria’s Global Reentry Depends on Domestic Reform
The process of sanctions relief will increasingly be shaped by the interplay between international expectations and Syria’s internal readiness. A sustainable reengagement strategy will depend not just on external deregulation but also on the Syrian transitional government’s capacity to cultivate trust, institutional stability, and legal clarity. Despite regional enthusiasm, from Gulf states eager to support Syria’s reentry into global financial systems to Turkey, European actors, and China signaling investment interest, foreign involvement remains tethered to the perception of credible governance.
President Ahmed al-Sharaa’s government must demonstrate it can meet international benchmarks on human rights, property rights, and anti-corruption enforcement to attract the capital necessary for reconstruction. However, the continued designation of Hay’at Tahrir al-Sham (HTS) as a terrorist organization by both the U.S. and the UN poses significant obstacles to international engagement. To overcome these challenges, the Syrian government needs to implement substantial reforms, including the fulfillment of the Caesar Act conditions, dealing with the question of foreign fighters, establishing inclusive governance structures and protection of minorities, and ensuring adherence to international norms and laws.
From Policy to Practice: Tangible Outcomes for Syrians
In this climate, the revival of Syria becomes a delicate exchange: international stakeholders await signs of credible reform yet will still need to take a leap of faith to unlock foreign investment, while many Syrians expect the interim authorities to demonstrate progress on legal and institutional reforms, political accountability, embark on transitional justice and start a long-term national healing process. Without bridging this trust gap, the lifting of sanctions may remain more symbolic than truly transformational.
Despite the momentum generated by the recent policy shifts, the road to meaningful recovery in Syria remains to be shaped by legislative hurdles, compliance risks, and institutional inertia both on the Syrian and international sides. For Syrians, progress will not be judged by diplomatic headlines but by daily realities, including job growth, accessibility and affordability of goods and services, and functioning public services. Efforts must prioritize rebuilding essential infrastructure, empowering small businesses, and strengthening local institutions. The question of security sector reform, however major and effortful, will be essential to stability and, hence, attracting foreign investment. Ultimately, whether in the short or long term, only by translating policy into tangible outcomes can the shared reconstruction effort by the international community, the Syrian authorities, the private sector, and the civil society organizations fulfill its promise to the broader Syrian population.