US Sanctions on Syria: Burdens of the Past and Future Possibilities

Introduction

After the Syrian revolution began in 2011, countries and organisations across the world slapped a raft of political and economic sanctions on the Assad regime. Their purpose was to force Assad to change his ways, and bring him to the negotiating table. The sanctions significantly weakened the regime’s grip on power – especially after America introduced the Caesar Syria Civilian Protection Act in 2019. Since Assad fled the country in December, the interim authorities have made repeated pleas for the international order, and most of all America, to lift sanctions on the country. They claim that the need for sanctions fell with the regime itself. Some activists have, however, pressed for caution. They believe sanctions may be key to holding the new authorities to account, and making sure that key human rights pledges are enshrined in Syria’s forthcoming constitution.

This analysis provides a concise summary of the history of America’s sanctions against the Assads – both Hafez and Bashar – and clarifies how these sanctions still target different sectors of Syrian economic and political life. The piece also examines consequences of sanctions faced by the new government that has taken Assad’s place, and sketches out future scenarios where sanctions remain a part of Syrian life – both at home and abroad.

American Sanctions vs. The Assad Regimes

• Before 2011

Sanctions first hit Hafez al-Assad in December 1979, as the regime – still in relative infancy – was providing support to Palestinian factions targeting American interests in Lebanon^[1]. The US put together a package of sanctions claiming that Syria was a “nation supporting terrorism” and banned arms sales to Syria as well as placing some financial barriers on the Syrian economy.

The second stage of US punitive measures began in 2003 under the “Syria Accountability and Lebanese Sovereignty Restoration Act” which was fully applied in 2004 during the George Bush era^[2]. Bashar al-Assad had, at that time, eased the crossing of fighters from Syria into Iraq to fight the US occupation. This set of sanctions targeted Syria in the following ways:

1. Militarily: most US arms exports to Syria were outlawed, and American companies were banned from working or investing in the country. The Assad regime was monitored if they tried to import any component parts that could have led to the production of significant arms.
2. Diplomatically: The Syrian diplomatic mission in Washington and New York was severely restricted in its movement.
3. Economically: Planes owned by the Syrian state were banned from taking off, landing or passing over American airspace, and American exports were banned in Syria – with the exception of medicine and foodstuffs.

At the time, the US president was granted the authority to exempt Syria from American export sanctions for six months, and was allowed to provide direct development assistance to the Syrian regime. To achieve this, the regime had to prove that they had stopped supporting armed resistance groups in Iraq, respected the sovereignty of Lebanon and stopped interfering in their neighbour’s internal affairs – which they failed to do. In 2005 US Ambassador Margaret Scobey was recalled from Damascus after the assassination of Lebanese premier Rafik al-Hariri. In the Obama era, diplomatic sanctions eased off in 2010 and diplomat Robert Ford was dispatched to reopen the US Embassy in Damascus.  

   It is possible to divide sanctions before 2011 into two types; firstly those enacted under the ‘anti-terror’ Patriot Act which targeted the Commercial Bank of Syria in 2006 and banned US institutions from doing business through the bank. The second category relates to sanctions against individuals engaged in cross-border activities in Iraq and Lebanon through regulations prepared by the US congress. The first category of sanctions expired in 2015, while the second remains active.

• Sanctions post 2011

With the onset of the Syrian revolution, the US recalled its embassy in Damascus in October 2011 after publicly alleging serious threats against their staff if the embassy remained open. Diplomatic relations between America and the regime were then frozen until Assad fled the country.

Other sanctions took hold incrementally from April 2011 onwards. They targeted individuals responsible for human rights violations, according to US statements^[3] at the time. Western sanctions en masse began in earnest in 2012, and increased throughout the 12 years leading to 2024. Despite targeting a wide range of Syrian institutions and individuals, the sanctions regime all aimed to restrict the regime’s military and security capabilities. They also identified economic cornerstones of the regime, both individuals and companies, to weaken the regime and force it to the negotiating table after years of refusal, and limit its ability to fund external militia. During this period, decisions were taken to monitor the Assad regime’s military tools and chemical capabilities. The US intelligence budget in 2014 included Article 324, which related directly to Assad’s chemical weapons arsenal – and included orders to collect information regarding the following^[4]:

• Chemical weapons stores, locations, methods of production and storage, and the development of new weaponry inside Syria;
• A list of key individuals involved in the production and maintenance of the chemical weapons programme;
• Undisclosed chemical stockpiles, munitions and facilities, as well as assessments of how materials and delivery systems were acquired
• Any intelligence gaps;
• Assad’s methods of denying the existence of chemical weapons programmes, and his means of misleading the international community.

This intelligence push came after the regime used Sarin gas to exterminate residents of eastern Ghouta in August 2013, and later handed over a portion of its arsenal through a Russian-American pact.

The US government also compelled the State Department to produce periodic reports on massacres occurring in Syria using clause 1232 of the National Defense Authorisation Act in 2019, in which Congress legislated that “the State Department must present reports on instances of war crimes, crimes against humanity and genocide in Syria.” In the following table, we can see that US sanctions took aim at three key pillars of the regime’s continued stability; individuals, institutions and processes.

Table 1: Dynamics of US sanctions in 2011 – 2012

The high point of US sanctions came at the announcement of the Caesar Act and associated powers in 2019, coming into effect in 2020. They went further than previous structures by targeting the regime’s financial and energy sectors directly, and froze a wide range of assets owned by individuals and entities tied to the Assad family. The Caesar sanctions defined the Syrian Central Exchange as a “money launderer” for the regime and, most crucially, targeted a wide range of Assad’s supporters – both Syrian and non-Syrian – in order to lay siege to the regime itself, cutting it off from the outside and turning up the economic heat.

The US granted three types of exemptions to the Caesar sanctions at different times:

1. Permits to Turkey for areas of development: these were granted for energy, defence, farming and education, solely for areas outside the control of the Assad regime, to allow for project investment from Turkish funders – on the proviso that they did not cooperate with anyone in the regime’s orbit to do so^[5].

• Emergency permits:
• COVID-19

The US government allowed for exceptional circumstances to override sanctions during the COVID-19 pandemic, allowing for the import of medical resources to halt the spread of the pandemic. This permit elapsed in June 2024^[6].

• Earthquake in February 2023

America also allowed Syrian authorities to exchange funds to support relief efforts in the aftermath of the earthquake; again with the proviso that no funds were transferred to sanctioned bodies or individuals. This permit elapsed in August 2023^[7].

• Permits for specific geographical regions:

Authorities in the north-east and north-west of Syria were granted specific permits in May 2022 covering many different sectors, including communications, infrastructure, education, import/export business of specific goods – permits which remain active today^[8].

Sanctions on Syria post-Assad

Assad’s fall from power coincided almost exactly with the expiry date of the Caesar sanctions. Despite this seismic moment, the US elected to extend the Caesar act by another five years on December 12, just days after Assad fled the country and the regime was swept away.

As soon as the former dictator left the shores of Syria, the new authorities – along with coterie of organisations and individuals from civil society – called publicly for the raising of sanctions, addressing America specifically. They claimed that the reason for the sanctions, namely Assad himself, had departed, and taken the need for sanctions along with him. The new regime expressed overt openness to US involvement, inviting a delegation of key figures to Damascus. The invitees included Daniel Rubenstein, Senior Advisor to the State Department’s Bureau of Near Eastern Affairs and Special Envoy to Syria, Assistant Secretary of State for Near Eastern Affairs Barbara Leaf, and Special Presidential Envoy for Hostage Affairs Roger Carstens – who all met with the new Syrian President Ahmed al-Sharaa. Their meeting precipitated the following changes:

• US authorities rescinded the bounty on information leading to the arrest of Ahmed al-Sharaa himself, a move swiftly welcomed by the new government^[9].
• US Secretary of State Anthony Blinken announced direct lines of communication between the Biden Administration and Hay’at Tahrir al-Sham, and confirmed that America would recognise the legitimacy of the new authorities depending on their adherence to key guiding principles.
• The State Department approved a new permit to loosen restrictions caused by the sanctions, for a period of six months, including across the energy sector – and even allowing the exchange of funds through the Syrian Central Exchange.

US policies since the fall of Assad express a cautious openness, and an attempt to retain a stable presence within the constellation of countries doing business with the new authorities whilst demurring from a complete restoration of ties. This correlates with the position of some Syrian rights activists, who believe that the carrot and stick of sanction may be a useful lever on the formation of a new government to build a political process that includes all Syrian groups. This shifts the goal of sanction from pressuring Assad himself to applying pressuring on the new power brokers – which carries two dimensions that may cause danger for Syria in the near future, namely:

1. It will not be possible for Syria to experience a period of transitional growth while sanctions remain, given the disastrous state of the economy and the reality of people’s daily lives inside the country – challenges which any new government will face.
2. The gravity of sanctions on the current government or any future powers will open the door for greater foreign intervention with more demanding conditions, in an effort to make or break the new Syrian economy

In the traditional US philosophy regarding sanctions, implementing them is far easier than lifting them – as we have seen most recently in Afghanistan.

The Fate of Sanctions after the Temporary License

The US announced a temporary easing of key restrictions for six months^[10] starting from 6 January until 7 July of this year, focusing on 4 key axes:

1. Allowing the authorities to fulfil basic functions of state, supplying essential needs to the nation and repairing key infrastructure such as energy and water supplies
2. Permitting cooperation with state bodies including the Ministry of Defence and security apparatus, administrative bodies and healthcare agencies
3. Easing restrictions on energy production and trade – both internally and externally
4. Opening the Syrian Central Exchange for personal financial transactions internationally, with the exception of individuals named on sanctions lists

Although the next phase in Syria has two key dimensions – the country’s economy, and the security of the state – authorities cannot begin to rebuild security and military infrastructures in the shadow of sanctions that define Syria as a terrorism-sponsoring state and forbid the trade of military hardware. Since 1979, these sanctions have outlawed export and defense sales to Syria until the introduction of the Caesar Act. If only the Caesar act is repealed, and other sanctions imposed pre-2011 left standing, Syria will not be able to fully begin a path of economic recovery and reliable self-governance. As  shown in the following table, demands for the repeal of sanctions in Syria should take the following steps:

Title: The necessary steps needed to lift US sanctions

Step 1: The removal Syria’s designation as “state sponsor of terrorism” announced in 1979

Step 2: Cancellation of the 2003 Syria Accountability and Lebanese Sovereignty Restoration Act

Step 3: Repeal sanctions placed on Syrian state institutions since 2011

Step 4: Lift the Caesar Act of 2019

The Syrian government needs to ensure the country is no longer designated as a state sponsor of terrorism, as many countries have been – such as Iraq, Yemen, Libya and Sudan in 2020. However, these countries were removed from the list on an ad hoc basis after adhering to US demands related to foreign policy over questions of internal structure of behaviour towards their citizens. Table 2 provides a general overview of steps taken to removal different countries from sanctions lists:

Table 2: Countries designated as sponsors of terrorism, and reasons for their removal

Aligning with its interests in the reason, we note that the US is interested in the following files, and may be part of any future proposal presented to the new Syrian leadership with a roadmap to lifting sanctions:

• Denying Iran a route to return to Syria, which aligns with the leadership already;
• Forgoing strong political ties with Russia with a view to restoring the Syrian military, and prioritising military ties to the US instead
• Respecting Israel’s security
• Negotiating with Kurdish-led Syrian Democratic Forces in Syria’s north-east
• Transforming any new Syrian army into a Western military force, rather than the Soviet/Russian blueprints which influences the formation of Syria’s last military.

Given the variety of international interests in Syria encountering the country’s fragile economic landscape, the following sanctions scenarios may emerge:

1. Successive permit extensions

In the event that the US relies on permit extensions to circumvent sanction restrictions, the Syrian state will remain in a limbo state of emergency, without the ability to embark on significant infrastructure projects to rebuild in a sustainable way. The threat of reintroduced sanctions will shackle economic momentum in essential sectors, and will deter international and regional organisations from seriously engaging with Syria. The country would be prevented from making long-term plans to rebuild the country from the ground up and reinvigorate the economy after years of war.

In addition, permit extensions do not allow assistance from international financial institutions such as the International Monetary Fund and the World Bank, and nor do they lift the embargo on properties and investments abroad owned by the Syrian government or the Syrian Central Bank. All Syrian assets outside the country would remain frozen which could lead to:

1. A lack of desire by the current leadership to form a government to take their place – currently due to happen in March 2025;
2. A re-opening of diplomatic links with Russia, accepting Russian overtures to return Syrian assets and invest in rebuilding the country;
3. An inability to rebuild the country’s army and military infrastructure, leading to fears that current security forces will become a faction serving the private ideologies of the leadership. For the US this would pose a particular threat to the security of Israel, and therefore lead to a refusal of lifting sanctions completely, and a continued reliance on permit extensions.

     2) A complete, gradual reversal of sanctions against Syria

This is the country’s ideal scenario, with respect to rebuilding the country’s economy, political institutions and healing the nation’s society after 14 years of civil war. This will be possible if the US administration designs and adheres to a clear roadmap with the transitional authorities, or any government which succeeds them, and raises sanctions gradually, alongside the following developments:

1. The US reaches an agreement with Turkey regarding the fate of the Syrian Democratic Forces, facilitating Syrian-American dialogue on the issue of north-eastern Syria. If this agreement is not reached, Turkey may consider any dialogue problematic – especially if the SDF enters a coalition government or forms a military bloc in the army rather than integrating as individuals; 
2. The Syrian government maintains limited diplomatic channels with Russia, without extending to high-level military and political coordination;
3. A pan-Arab movement arises to lift sanctions on Syria through diplomatic channels and obtaining permits to work in the country – especially led by Saudi Arabia and Qatar.

In addition, there must be an internal effort by Syria to engage with international partners wishing to work in Syria, and communicate effectively with the US administration on the following two levels:

1. Using the Office of Foreign Assets Control to obtain individual licenses and exemptions in specific sectors^[11];
2. Pushing to expedite the process by which licenses are approved by the US – similar to actions taken by the US Department of Trade after the earthquake of 2023, and permits were accelerated unilaterally for exports to Syria during the exemption window^[12].

     3) No permit extensions, no sanctions lifted

In the scenario, Syria enters a phase of further economic, political and social instability, and international assistance efforts are undermined. Only food and medical aid is allowed in, while cities remain in ruins, unable to receive returning refugees. On the level of international relations, the effect of leaving sanctions in place would affect the following files:

1. The Captagon trade: The Assad regime tried to exploit the trade of Captagon and other drugs, using allied militias to destabilise regional security – especially neighbouring countries such as Jordan. Those militias remain at large, but are currently inactive due to the role played by the new authorities in limiting Captagon production and pledging that Syria will no longer be a drug exporter. If there is no sign of economic recovery, however, and any new government loses the ability to enforce the rule of law due to persisting sanctions, these militias will return to their activities, taking Syrian society with them. The trade of Captagon has been hugely lucrative in the wake of mass unemployment, economic instability and the continued sanctions.
2. The role of Iran: The fall of the Assad regime struck a huge blow to Iran’s regional interests, leaving a gap in Iran’s land route to Lebanon. Iranian products have always been a target for markets sanctioned by Europe and the United States, including China. Any continued sanctions may reopen the door for Iran back into Syria, reactivating local militias loyal to Iran’s ideology.
3. Russian influence: Russia has cast a long shadow in Syria ever since the Ba’athist coup of 1963. Their most prominent role has been in shaping Syria’s military and supplying its hardware. This stream of equipment was steady and significant, given Syria’s good relationship with the Soviet Union and the favourable price difference with Western weaponry. This support continued right until the fall of Assad – and now Israeli strikes have laid waste to a large percentage of Syria’s military capabilities. Therefore, efforts to rebuild the army are at a crossroads; and maintaining sanctions on armaments and military equipment may force the return of Russia’s military role in Syria, in the absence of any other viable alternatives.

Conclusion

The foundations of American sanctions in Syria, since their onset in 1979, have always been underpinned by the US rivalry with Russia. Both Assads further provoked American rancour, starting with Hafez al-Assad’s occupation of Lebanon and his close alliance with Iran, through to his son’s interventions in Iraq through various militias post-2003. After the regime’s involvement in the assassination of Lebanese PM Rafik al-Hariri in 2005 and climaxing with Bashar al-Assad’s repression of the Syrian people from 2011 onwards, relations with the US were on a path of no return. On the international stage, Assad threatened the stability of Syria’s neighbours as leverage, and broke international embargoes on several occasions.

Now, all evidence suggests that US sanctions no longer have a purpose to serve. If rules originally created to curb the worst excesses of the Assad regime are used to apply leverage on Syria’s new rulers to impose international interests on Syria, it may lead to economic catastrophe. The country may continue to spiral into stagnation, without the ability to build a national project. In the shadow of sanctions, Syria cannot hope to chart a long-term plan for recovery. The military and security apparatus urgently need material support after years of neglect and destruction. Continued sanctions will leave Syria a fragile state – both economically and militarily. They will leave the country exposed to the activities of criminal gangs trading in drugs, further degrading the country’s security and the security of its neighbours. Ultimately, US sanctions in a new Syria will reopen the door to Russia and Iran’s influence in the region, at a time when they are both waning.

References:

• US Department of state, U.S.-Syria Relations
• US Congress, H.R.1828 – Syria Accountability and Lebanese Sovereignty Restoration Act of 2003
• S.Hrg. 112-365 — U.S. POLICY IN SYRIA
• US Congress, S.1681 – Intelligence Authorization Act for Fiscal Year 2014, DEC 2013
• Office of Foreign Assets Control, GENERAL LICENSE 3, Authorizing Official Activities of Certain International Organizations Involving the Ministry of National Defense or the Ministry of Energy and Natural Resources of the Government of Turkey
• Office of Foreign Assets Control, Syria General License 21B, Authorizing Certain Activities to Respond to the Coronavirus Disease 2019
• Office of Foreign Assets Control, Syria General License 23, Authorizing Transactions Related to Earthquake Relief Efforts in Syria,
• Office of Foreign Assets Control, GENERAL LICENSE NO. 22, Authorizing Activities in Certain Economic Sectors in Non-Regime Held Areas of Northeast and Northwest Syria
• Office of Foreign Assets Control, GENERAL LICENSE NO. 24, Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances
• Office of Foreign Assets Control, Specific Licenses and Interpretive Guidance
• Bureau of Industry and Security, Commerce Announces Expedited Licensing for Exports to Assist in Earthquake Relief, February 17 2023, US DOC website

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^[1]  US Department of state, U.S.-Syria Relations, https://www.state.gov/countries-areas/syria/

^[2] US Congress, H.R.1828 – Syria Accountability and Lebanese Sovereignty Restoration Act of 2003, https://bit.ly/3PEgzRg

^[3] S. Hrg. 112-365 — U.S. POLICY IN SYRIA, https://bit.ly/3Q2hDyz

^[4]  US Congress, S.1681 – Intelligence Authorization Act for Fiscal Year 2014, DEC 2013, https://bit.ly/40KbHiJ

^[5] Office of Foreign Assets Control, GENERAL LICENSE 3, Authorizing Official Activities of Certain International Organizations Involving the Ministry of National Defense or the Ministry of Energy and Natural Resources of the Government of Turkey https://bit.ly/40MM8NY

^[6]  Office of Foreign Assets Control, Syria General License 21B, Authorizing Certain Activities to Respond to the Coronavirus Disease 2019 (COVID-19), https://bit.ly/4aN45R1

^[7] Office of Foreign Assets Control, GENERAL LICENSE NO. 22, Authorizing Activities in Certain Economic Sectors in Non-Regime Held Areas of Northeast and Northwest Syria https://bit.ly/4hpRBBE

^[8] Office of Foreign Assets Control, GENERAL LICENSE NO. 22, Authorizing Activities in Certain Economic Sectors in Non-Regime Held Areas of Northeast and Northwest Syria https://bit.ly/4hpRBBE

^[9] US lifts $10m bounty on HTS leader after talks in Syrian capital, The Guardian US, 20 December 2024: ttps://bit.ly/3WN0Bbs

^[10] Office of Foreign Assets Control, GENERAL LICENSE NO. 24, Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances, https://bit.ly/4jGq28x

^[11]  Office of Foreign Assets Control, Specific Licenses and Interpretive Guidance, https://bit.ly/4gpVyF1

^[12] Bureau of Industry and Security, Commerce Announces Expedited Licensing for Exports to Assist In Earthquake Relief, https://bit.ly/42FJwnO

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