Overview
UN Sanctions
In 2005, by UN Resolution 1636 (still in force today), the UN imposed travel bans and asset freezes on people suspected of being involved in the 14 February 2005 terrorist bombing in Beirut, Lebanon, in which Syria was implicated by a UN report.
EU Sanctions
The EU implemented the UN’s travel ban and asset freeze sanctions in 2005 by Common Position 2005/888/CFSP and Council Regulation (EC) No 305/2006.
In 2011, the EU established an autonomous sanctions regime in response to the Syrian government’s violent repression of civilians.
In response to further violence, and the illegal removal of goods belonging to Syria’s cultural heritage additional sanctions measures were introduced in 2013/2014.
The EU designates people who are leading businesspersons operating in Syria; responsible for the Syrian regime’s violent repression against the civilian population; provide support to the Syrian regime and the Syrian army; provide benefit from the Syrian regime; assist in the production and development of chemical weapons for the Syrian regime; organize chemical weapons attacks; are senior officers of the Syrian Armed Forces and the Syrian security and intelligence services; and are members of Syrian regime-affiliated militias. The current EU sanctions are in Council Decision 2013/255/CFSP and Council Regulation (EU) No 36/2012.
DPs may be removed from the EU Syria sanctions list if there is sufficient information that they are not, or are no longer, associated with the regime or do not exercise influence over it or do not pose a real risk of circumvention.
UK Sanctions
UK sanctions are in the Syria (Sanctions) (EU Exit) Regulations 2019.
US Sanctions
Syria has been designated by the US on the State Sponsor of Terrorism List since December 1979, which results in a ban on defence exports and sales; certain controls over exports of dual use items; and miscellaneous financial and other restrictions.
Additional import and export controls were introduced in May 2004 by the Syria Accountability and Lebanese Sovereignty Restoration Act, and assets freezes were imposed in 2011. Current US sanctions are contained within EO 13894, consisting of an arms embargo, assets freeze, and travel bans.
Current UN Sanctions
In 2005, by UN Resolution 1636 (still in force today), the UN imposed travel bans and asset freezes on people suspected of being involved in the 14 February 2005 terrorist bombing in Beirut, Lebanon, in which Syria was implicated by a UN report.
Current EU Sanctions
The EU implemented the UN’s travel ban and asset freeze sanctions in 2005 by Common Position 2005/888/CFSP and Council Regulation (EC) No 305/2006.
In 2011, the EU established an autonomous sanctions regime in response to the Syrian government’s violent repression of civilians.
In response to further violence, and the illegal removal of goods belonging to Syria’s cultural heritage additional sanctions measures were introduced in 2013/2014.
The EU designates people who are responsible for the Syrian regime’s violent repression against the civilian population; provide support to the Syrian regime and the Syrian army; provide benefit from the Syrian regime; assist in the production and development of chemical weapons for the Syrian regime; organize chemical weapons attacks; are senior officers of the Syrian Armed Forces and the Syrian security and intelligence services; and are members of Syrian regime-affiliated militias. The current EU sanctions are in Council Decision 2013/255/CFSP and Council Regulation (EU) No 36/2012.
- Legislation
- Sanctions List
- Guidance
- Judgments
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T-370/23 Al-Assad v Council
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T‑209/22 Makhlouf v Council
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T‑208/22 Makhlouf v Council
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T-207/22 Mhana v Council
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T-206/22 Makhlouf v Council
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T‑649/22 Shammout v Council
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T-471/22 Anbouba v Council
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C‑524/22 Foz v Council
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T-426/21 Assaad
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T-479/21 Haswani
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T-296/20 Foz
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T-249/20 Sabra
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T-256/19 Assi
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T-257/19 Al Zoubi
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T-258/19 Foz
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T-259/19 Aman Dimashq JSC
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T-218/20 Alkattan
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T-203/20 Al-Imam
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T-540/19 Sharif
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T-260/19 Al-Tarazi
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T-521/19 Haswani
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T-189/19 Haikal
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T-178/19 Kalai
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C-157/19 P Makhlouf
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C-350/19 P Souruh SA
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C-349/19 P Almashreq Investment Fund
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C-348/19 P Drex Technologies
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C-261/19 P – Cham Holdings
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C-260/19 P Bena Properties
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C-159/19 P Syriatel Mobile Telecom
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C-158/19 P Othman
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T-510/18 Kaddour
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C-241/19 P Haswani
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T-186/19 Zubedi
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C-540/18 HX
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T-5/17 Sharif
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T-414/16 Drex Technologies SA
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T-440/16 Souruh SA
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T-415/16 Almashreq Investment Fund
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T-667/17 Alkarim for Trade and Industry LLC
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T-559/17 Abdulkarim
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C-313/17 P Haswani
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T-412/16 Bena Properties
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T-413/16 Cham Holding
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T-477/17 Haswani
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T-409/16 Makhlouf
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T-416/16 Othman
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T-411/16 Syriatel Mobile Telecom
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T-408/16 HX
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C-458/17 P Makhlouf
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T-461/16 Kaddour
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T-410/16 Makhlouf
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T-303/15 Barqawi
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T-304/15 Abdulkarim
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T-719/14 Tri Ocean Energy
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T-830/14 Farahat
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T-709/14 Tri-Ocean Trading
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T-790/14 Hassan
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T-723/14 HX
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C-193/15 P Akhras
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T-443/13 Makhlouf
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T-153/15 R Hamcho
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T-154/15 R Jaber
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T-155/15 R Kaddour
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T-593/11 Al-Chihabi
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C-605/13 P Anbouba
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C-630/13 P Anbouba
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T-652/11 Sabbagh
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T-579/11 Akhras
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T-509/11 Makhlouf
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T-654/11 Kaddour
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T-43/12 Hamcho & Hamcho International
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T-653/11 Jaber
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T-307/12 Mayaleh
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T-572/11 Hassan
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T-329/19 Al-Tabbaa
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T-203/12 Alchaar
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T-293/12 Syria International Islamic Bank
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T-202/12 Al Assad
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T-174/12 Syrian Lebanese Commercial Bank
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T-383/11 Makhlouf
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T-563/11 Anbouba
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T-592/11 Anbouba
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T-572/11 R II Hassan
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T-572/11 R Hassan
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T-593/11 R Al-Chihabi
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T-579/11 R Akhras
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Current UK Sanctions
UK sanctions are in the Syria (Sanctions) (EU Exit) Regulations 2019.
- Legislation
- Sanctions List
- Guidance
- Judgments
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Nassani & Ors, R (On the Application Of) v Secretary of State for Foreign, Commonwealth And Development Affairs [2023] EWHC 2853 (Admin)
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R (Certain Underwriters at Lloyds London & Ors) v HM Treasury [2020] EWHC 2189 (Admin)
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Hmicho v Barclays Bank [2015] EWHC 1757 (QB)
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Current US Sanctions
Syria has been designated by the US on the State Sponsor of Terrorism List since December 1979, which results in a ban on defence exports and sales; certain controls over exports of dual use items; and miscellaneous financial and other restrictions.
Additional import and export controls were introduced in May 2004 by the Syria Accountability and Lebanese Sovereignty Restoration Act, and assets freezes were imposed in 2011. Current US sanctions are contained within EO 13894, consisting of an arms embargo, assets freeze, and travel bans.
- Legislation
Caesar Syrian Civilian Protection Act of 2019
Iran Threat Reduction and Syria Human Rights Act of 2012
EO 13894 – Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria (October 14, 2019)
- Sanctions List
Search “Syria” on the OFAC SDN List
- Guidance
Guidance for the Provision of Humanitarian Assistance to Syria (August 8, 2023)
Guidance to Address Illicit Shipping and Sanctions Evasion Practices (May 14, 2020)
Non-English Translations of this Guidance
Updated Guidance on Sanctions Risks Related to Shipping Petroleum to Syria (March 25, 2019)?
Sanctions Risks Related to Shipping Petroleum to Syria? (November 20, 2018)
- Resolutions
Syria-related General License 1 – Official Business of the United States Government
Other Countries Sanctions
- Judgments
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Kuvera Resources Pte Ltd v JPMorgan Chase Bank NA [2023] SGCA 28
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Kuvera Resources Pte Ltd v JPMorgan Chase Bank, NA [2022] SGHC 213
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