On January 6, 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 24, a time-limited GL which authorizes, inter alia, certain transactions with governing institutions in Syria that are otherwise prohibited by the Syrian Sanctions Regulations (SySR), the Global Terrorism Sanctions Regulations (GTSR) and the Foreign Terrorist Organizations Sanctions Regulations (FTOSR). 

In its press release announcing the GL, OFAC stated that "[g]iven the extraordinary circumstances, and to support the Syrian people as they build a more hopeful, secure, and peaceful future... OFAC... is issuing GL 24 to help ensure that sanctions do not impede essential services and continuity of governance functions across Syria." GL 24 comes approximately one month after the fall of the Assad regime in Syria, an offensive spearheaded by Hay'at Tahrir al-Sham (HTS), a paramilitary organization which itself is designated by OFAC (as well as by the United Nations) under the GTSR and the FTOSR due to former and alleged ties to Al Qaeda. HTS is now Syria's de facto sovereign and, given its multiple OFAC designations, in the absence of GL 24, U.S. persons could not transact with Syria's new government, even under existing GLs issued under the SySR.

Specifically, GL 24 authorizes, until July 7, 2025:

• Transactions with governing institutions in Syria following December 8, 2024 
• Transactions in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products, natural gas, and electricity, to or within Syria
• Transactions that are ordinarily incident and necessary to processing the transfer of non-commercial, personal remittances to Syria, including through the Central Bank of Syria

While GL 24 does not broadly authorize financial transfers to blocked persons in Syria, including to HTS, it does authorize such transfers that are for the purpose of effecting payment to governing institutions in Syria of taxes, fees, or import duties, the payment of salaries or wages of non-blocked Syrian governing institution employees, or the purchase or receipt of permits, licenses, public utility services, or other public services in Syria. Alongside GL 24, OFAC issued a handful of new or amended Frequently Asked Questions (FAQs) regarding the scope of the GL. For example, FAQ 1207 describes certain transactions that may fall under GL 24, such as providing services to, or paying for services from, the Syrian Ministry of Health, the Ministry of Education, or the Ministry of Water Resources, payment of taxes, fees, or duties to the Syrian government, purchase or receipt of permits, and negotiating agreements with Syrian governing institutions, among other activities.

Key Takeaways

• Sanctions relief in the form of GL 24 is narrow and time-limited. GL 24 is a six-month license which contains many carveouts. The license does not allow for transactions involving the Syrian military or intelligence entities, new investment in Syria, or other any other transactions involving blocked persons or other blocked governments.
• Other humanitarian GLs under the SySR still exist. In its FAQs, OFAC made clear that GL 24's authorization may overlap with existing GLs issued under the SySR, the GTOSR, or the FTOSR, including GLs authorizing non-commercial personal remittances, non-governmental organization (NGO) activity, official business of the U.S. government, or certain activities related to the export of agricultural commodities, medicine, or medical devices.
• Syria still remains subject to comprehensive sanctions despite the fall of the Assad regime and the situation on the ground is fluid. OFAC makes clear that Syria is still one of OFAC's "most comprehensively sanctioned jurisdictions" and that GL 24 is meant to ensure sanctions do not impede humanitarian needs while the U.S. government "continues to monitor" the situation. Assuming no major changes in rule in Syria, we would expect OFAC to renew GL 24. However, we caveat that the incoming Trump administration could decide to reverse that course or alter U.S. foreign policy with respect to Syria. Entities with even tangential ties to Syria should tread cautiously in continuing or expanding business in Syria, while closely monitoring current events in the region and the larger Middle East.

For more information, please contact:

Timothy P. O'Toole, totoole@milchev.com, 202-626-5552

Melissa Burgess, mburgess@milchev.com, 202-626-5914

Laura Deegan, ldeegan@milchev.com, 202-626-5942

Caroline J. Watson, cwatson@milchev.com, 202-626-6083

Manuel Levitt, mlevitt@milchev.com, 202-626-5921

Annie Cho, acho@milchev.com, 202-626-1570

Peter Kentz, pkentz@milchev.com, 202-626-5891

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