EU Court rejects Amer Foz’s applications to annul his 2024 and 2025 entries on EU Syria list

9 December 2025

The EU General Court has rejected a delisting application brought by Amer Foz, challenging his 2024 and 2025 relisting on the EU’s Syria sanctions list under Regulation (EU) 36/2012 – Case T‑414/24; judgment summary.

Previous judgment

Amer Foz was first sanctioned by the EU in 2020 under the leading businessperson criterion in Article 15 (1a)(a) of Regulation 36/2012. His original listing said he was:

• a leading businessperson in Syria who benefits from and supports the Syrian regime; and

• associated through business links with his brother, Samer Foz, who has been EU sanctioned since 2019 for his association with the Syrian regime.

In 2021, the EU amended his listing to say that Mr Foz had, with his brother, traded with ISIL on behalf of the Syrian regime, including providing weapons and ammunition in exchange for wheat and oil. This was based on a Pro‑justice report showing Mr Foz’s company Aman Holding’s role in grain transport and brokerage for the regime. His 2021 relisting also added details of commercial projects in the Adra al‑Ummaliyya area. Mr Foz unsuccessfully challenged his 2020 listing and 2021 relisting in Case T-296/20; judgment upheld on appeal in C‑524/22 P.

In 2023 and 2024, the EU amended Amer Foz’s designation to remove reference to Aman Holdings. In 2025, following the fall of the Assad regime, the EU amended Mr Foz’s designation based on the updated designation criterion in Article 15, i.e. for being a “leading businessperson operating in Syria linked to the former al-Assad regime”. When amending the designation criteria, the EU said leading businesspeople linked to the former Syrian regime “continue to hold powerful influential roles and pose a risk of supporting … further armed conflict” in Syria. Mr Foz’s 2025 relisting said he was:

• a leading businessperson in Syria linked to the former regime of Bashar Al-Assad who benefits from and supports the former regime; and

• associated with his brother, and together, they engaged in various activities with ISIL on behalf of the former regime.

His 2025 relisting removed reference to the Adra al‑Ummaliyya project. Mr Foz challenged his 2024 and 2025 relistings.

2024 relisting

The Court rejected his application to annul his 2024 relisting because:

• The Pro‑justice report which showed Mr Foz’s links to the ISIL trade remained relevant because the situation in Syria had not changed since his earlier listings. Although Aman Holding was removed from Mr Foz’s statement of reasons in 2023, the report was still used to substantiate the unchanged allegation that Mr Foz and his brother engaged in activities with ISIL on behalf of the Syrian regime [69–72, 98].

• Mr Foz was not designated only for family ties, because he shared business interests with his brother [83].

• The EU could not rely on the Adra al‑Ummaliyya projects because it failed to provide sufficient evidence that the brothers jointly implemented them [95].

• The court also accepted that other evidence, including links to a cousin of Bashar al‑Assad, justified a finding that Mr Foz was associated with the Syrian regime [109].

2025 relisting

The Court also rejected his application to annul his 2025 listing because:

• The Pro‑justice report on ISIL trade was no longer relevant because the fall of the Assad regime had changed the context and no new evidence linked Mr Foz to ISIL [132, 142].

• The designation was nonetheless lawful because Mr Foz and his brother had relocated to Dubai, maintained business ties, and jointly invested in properties and Lebanese firms and the EU had evidence that showed they were among former regime‑linked businessmen who acquired luxury real estate in Dubai [151].