The suspension is intended to “[…] facilitate engagement with the country, its people and businesses in areas of energy, transport and reconstruction, as well as to facilitate the associated financial and banking transactions.” At the same time, the Council decided that  “[…] listings related to the Al-Assad regime, the chemical weapons sector and illicit drug trade as well as a number of sectoral measures, such as on arms trade, dual-use goods, equipment for internal repression, software for interception and surveillance, and the import/export of Syrian cultural heritage goods should be maintained.” 

The Council’s decision is subject to the continued monitoring by the EU and dependent on further political developments within Syria, as a 11 March 2025 statement regarding recent violence illustrates. This Insight discusses these developments.

Overview of suspended measures 

Overview of measures remaining in force

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Individual Restrictive Measures

• Lifting of asset freezes – The six following significant entities were removed from Annex II of the Regulation, lifting therefore the asset freeze measures targeting them: 
  
  • Industrial Bank
  • Popular Credit Bank 
  • Saving Bank 
  • Agricultural Cooperative Bank 
  • Central bank of Syria 
  • Syrian Arab Airline
    
    • Consequently, as of today, 361 individuals and 89 entities remain subject to EU asset freeze measures.  
• ‍Remaining Central Bank of Syria asset-freeze – The assets located outside Syria as of 27 February 2012, owned, held or controlled by the Central Bank of Syria (listed in the new Annex IIb remain however frozen. 
• ‍Extension of existing humanitarian exemption  – The asset freeze measures do not apply when funds or economic resources are necessary to ensure the timely delivery of humanitarian assistance or to support other activities that support basic human needs. The 1 June 2025 deadline was removed, extending, de facto, this humanitarian related exemption.

Sectoral Sanctions

• Luxury goods ‍
  • ‍New exemption – Export prohibition targeting luxury goods (as listed in Annex X) does not apply anymore for personal travel from the EU.
• ‍Financial sanctions ‍
  • ‍New exemptions – The financial prohibitions laid down in article 25 of the Regulation related to (i) the opening of a bank account, (ii) the establishing a new correspondent banking, (iii) the opening a new representative office in Syria and (iv) the creation of a new JV, with any Syrian credit or financial institution and (v) related transactions, do not apply anymore when: 
    • These activities are performed for the purpose of providing assistance to the Syrian population as regards:
      • the delivery of humanitarian assistance or to support other activities that support basic human needs, the provision of basic services, or other civilian purposes; or
      • the reconstruction, stabilisation, restoring economic activity, institution-building, the provision of basic services, or other civilian purposes.
    • They are performed in connection with:
      • the import, purchase or transport of crude oil or petroleum products from Syria to the Union;
      • the construction or installation of new power plants for electricity production in Syria;
      • the provision of financial services (including the creation of a JV) to entities engaged in the exploration, production or refining of crude oil or the construction or installation of new power plants for electricity production in Syria; 
      • the sale, transfer, or export of jet fuel or jet fuel additives to any person in Syria or for use in Syria; 
      • the provision of access to airports in the Union for exclusively cargo flights operated by Syrian carriers; 
      • the export of new Syrian denominated banknotes and coinage to the Central Bank of Syria.

Conclusion 

The suspension of sanctions are geared towards allowing EU operators to engage with the Syrian economy for precisely the purpose of reconstruction. Sanctions in the energy and construction sectors as well as the infrastructure sector have therefore been provionnally lifted. Some activities nevertheless require the authorisation of the national competent authorities in order for them to ensure that any economic activity by EU operators in the country is geared towards the reconstruction of the Syrian economy and the assistance of the local population. The recitals note that the situation in the country is being continuously monitored with the aim to assess the appropriateness of the continued suspension sanctions. The EU reserves the option to re-impose the measures depending on the political developments within Syria in the time to come.  

In a statement on behalf of the European Union dated 11 March 2024 on the recent wave of violence in Syria, the High Representative noted that “[t]he EU recalls its recent suspension of restrictive measures as part of a gradual, reversible approach. The EU will continue to examine possible further sanctions suspensions on the basis of close monitoring of the situation in the country.” In this dynamic geopolitcal context, EU operators should continue to monitor developments and perform appropriate risk-based due diligence.

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