The majority of the sanctions against Syria were lifted in 2025 following the fall of the Assad regime. However, certain individuals and entities remain subject to asset freeze measures so that each transaction will need to be evaluated carefully.
EU
The EU in 2025 relaxed its sanctions against Syria and now most energy-related transactions are authorized. Council Regulation (EU) No 36/2012 was the regulation containing the prohibitions. The Council Regulation (EU) 2025/407 has now suspended the previous prohibitions contained in: Articles 6, 6a, 6b, 7, 7a, 8, 9, 9a, 10, 11, 12, 13, 13a, 21a, 21b and 26a.
On 28 May 2025, the European Council then lifted nearly all remaining sectoral sanctions on Syria. In particular, in addition to delisting 24 entities from the list of EU Designated Persons (now including the Syrian Central Bank), the EU has also completely lifted most other previously applicable sectoral restrictions (see the amending regulation here).
Several key restrictions remain in place, including:
- Security-related measures, including the arms embargo and export controls on equipment that could be used for internal repression;
- The designation of individuals and entities linked to the Assad regime; and
- New listings under the EU Global Human Rights Sanctions Regime in response to the violence in Syria in March 2025, targeting two individuals and three entities for serious human rights violations.
United States
In August 2025 the US Office of Foreign Assets Control has published a final rule revoking the Syrian Sanctions Regulations.
The US revoked its sanctions on Syria on 30 June 2025 – see EO 14312.
EO 14312 announced a policy change towards Syria, President Trump announcing that the circumstances which gave rise to the Syria sanctions had changed in the months since Syria’s regime change.
The final rule means that as of 26 August 2025, the Syrian Sanctions Regulations are repealed. Sanctions on members of the former Assad regime remain in force.
UK
The restrictions are contained in the Syria (Sanctions) (EU Exit) Regulations 2019.
The Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025 ( "Amending Regulations"), were subsequently published on 25 April 2025 and took effect the same day. The Explanatory Memorandum to the Amending Regulations explains that sanctions on key sectors (including energy, transport and financial services) are being lifted with the aim of promoting peace, stability and the rule of law in Syria. In particular, the Amending Regulations remove prohibitions in relation to:
- Import of crude oil and petroleum products which originate or have been consigned from Syria;
- Investment in crude oil and electricity production;
- Various activities in the financial sector, including for example establishing a correspondent banking relationship with Syrian financial institutions;
- Provision of insurance services to the Syrian regime (as defined); and
- Export, supply or delivery of aviation fuel, goods and technology relating to crude oil and natural gas, goods relating to electricity production, and bank notes or coinage (and the provision of ancillary services).
Although sanctions on several key Syrian entities have been lifted, a number of designated persons (almost all individuals) remain subject to asset freezes. The sanctions that remain in place aim to ensure that the UK Regulations are "fit for purpose" and maintain accountability for human rights violations committed during the Assad regime.
The Amending Regulations also maintain trade prohibitions on trade in:
- gold, precious metals and diamonds;
- military / internal repression goods and technology;
- interception and monitoring goods and services; and
- the export of goods relating to chemical and biological weapons.
In respect of the continuing Syria asset freeze, OFSI General Licence INT/2025/5810196 (the "GL") remains available to permit activities necessary to provide humanitarian assistance or support basic human needs in Syria. Any companies seeking to rely on the GL should ensure that they have carefully considered its terms and comply with the GL's notification requirements.
Norway
In July 2025 Norway has implemented legal acts to lift sanctions against Syria. Norway decided to align itself with the EU’s decision of May 27 to lift most of the sanctions against Syria. Sanctions targeting key individuals in former President Bashar al-Assad’s regime will remain in place.
The sanctions on Syria are implemented in the Regulation of September 2, 2011 No. 902 on restrictive measures against Syria.
Rules and cover
Members and clients must do their own due diligence and the position remains that while Skuld can give guidance, the ultimate responsibility for compliance rests with members and clients.
Our rules contain exclusion of liability for liabilities, costs or expenses where payment by the Association or the provision of cover in respect thereof may expose the Association to the risk of being subject to a sanction, prohibition or any adverse action (Rule 30.4.6).
We also remind that we exclude the liability of the Association towards the member when there is a shortfall due to an inability to recover reinsurance or pool contributions from other insurers or P&I Clubs which are themselves unable to pay due to sanctions legislation (Rule 32.6). In addition, we have a provision giving the Association the right to terminate cover where, in the opinion of the Association, the member has exposed or may expose the Association to the risk of being or becoming subject to a sanction, prohibition, restriction or other adverse action by a state or international organisation or competent authority (Rule 3.3.2 e). The same provisions are also included in the Terms & Conditions governing Skuld's fixed premium covers.
We also continue to experience difficulties in executing payments to Syria due to ongoing banking restrictions and compliance challenges. These issues may affect the availability and reliability of payment channels and provision of security. We advise members and clients to anticipate potential challenges and to consult with their financial institutions for guidance on transaction feasibility.