A merican Club Circular No . 19 / 25 1 JULY 14, 2025 CIRCULAR NO. 19/25 TO MEMBERS OF THE ASSOCIATION Dear Member: SANCTIONS UPDATE – U.S. REMOVES MOST SANCTIONS RELATED TO SYRIA This circular provides an overview of the revocation of most Syria-related sanctions by the United States, based on publications from the U.S. Department of the Treasury (Treasury) and the Office of Foreign Assets Control (OFAC). On June 30, 2025, President Trump issued an Executive Order (E.O.) “Providing for the Revocation of Syria Sanctions” (the June 30 E.O.) effectively unblocking hundreds of individuals and entities on the List of Specially Designated Nationals and Blocked Persons (SDN List), and relaxing certain restrictions on exports to Syria effective July 1, 2025. According to a press release by Treasury the reason for the changes stems from positive developments in Syria over the past six months which have “transformed” the circumstances that gave rise to the former sanctions program. The June 30 E.O. also amends E.O. 13894, preserving and expanding OFAC's ability to sanction former Syrian president Bashar al-Assad and his associates, human rights abusers, Captagon traffickers, persons linked to Syria's past proliferation activities, ISIS and Al-Qa'ida affiliates, and Iran and its proxies. Accordingly, the OFAC Syria-related sanctions program has now become the Promoting Accountability for Assad and Regional Stabilization Sanctions (PAARSS) program. Key developments and effects 1. The six Executive Orders that formed the foundation of the Syria sanctions program (SySR) have been revoked. Consequently, OFAC will be removing the SySR from the Code of Federal Regulations (CFR). The E.O.s which were terminated were: (1) E.O. 13338 of May 11, 2004; (2) E.O. 13399 of April 25, 2006; (3) E.O. 13460 of February 13, 2008; (4) E.O. 13572 of April 29, 2011; (5) E.O. 13573 of May 18, 2011; and (6) E.O. 13582 of August 17, 2011. Pending or future OFAC investigations or enforcement actions related to apparent violations of the SySR that occurred prior to July 1, 2025, may still be carried out. OFAC’s General License (GL) 25, which previously allowed certain otherwise prohibited transactions under the now-revoked Syria Sanctions Regulations (SySR), may still be relied upon where needed. However, many of its provisions are now redundant following the June 30 E.O. Persons may also continue to rely on the related Syria GL 25 Fact Sheet issued on May 28, 2025 (now updated to include language regarding the June 30 E.O). A merican Club Circular No. 19 / 25 2 As of July 1, 2025, U.S.-origin food and medicine can be exported to Syria without an OFAC license. Previously, only U.S.-origin food and medicine classified as EAR99 under the Department of Commerce’s Export Administration Regulations (the EAR) could be exported to Syria without authorization. However, as FAQ 1222 points out, now anyone may send U.S.-origin food or medicine to Syria without a specific OFAC license. That said, the Department of Commerce maintains jurisdiction over the export of most items to Syria, so members should consult the BIS website for updates. 2. OFAC has removed hundreds of individuals and entities from the SDN List sanctioned under the Syria sanctions program. Persons designated solely pursuant to the six E.O.s that form the foundation of the SySR have been removed from OFAC’s SDN List. All property and interests in property of such individuals and entities are unblocked. To see a full li