While the US and EU have been slow to lift sectoral sanctions on Syria, the UK has been even slower.
25 MARCH 2025
“Optimism is the pragmatic response.”
That was the message Simon Collis had for the Foreign Affairs Committee at their recent evidence session on Syria. He was the last British ambassador to Syria, closing the embassy in February 2012.
On today’s new government in Syria, he said, “There are clearly risks, but there is nothing to be gained by the UK or other countries with any potential influence sitting back to wait and see, and then having the satisfaction of eventually being proved right about our pessimism.”
He argued that the UK should lift sanctions, not necessarily sanctions against Hayat Tahrir al-Sham, the armed group that had led the final offensive against Assad, but lift the sectoral sanctions against Syria.
“I see no basis for the sanctions against Syria as a country to be maintained,” he told the Committee. “They were put in place because of the actions of the previous regime, the Assad regime. That regime is gone—the justification for the sanctions is gone.”
And he criticised the suggestion of taking an incremental approach, “as if it is a dial that you can fine tune,” which he believed was dangerously mistaken. “There are humanitarian reasons for this, there are legal reasons for this, but it is also pragmatic politics. If it all goes wrong, sanctions can be brought back; there is nothing to stop them being brought back, but this is a period to give the people in Syria the best chance of moving forward.”
“That regime is gone—the justification for the sanctions is gone”
Simon Collis giving evidence to the Commons Foreign Affairs Committee, 28 January 2025.
The Government, it seems, has not heeded this advice. Where the US and EU have been slow to lift sanctions on Syria, the UK has been slower still.
On the 6th of January, almost a month after Assad’s flight to Moscow, the United States Treasury moved to ease sanctions against Syria, issuing General License 24, valid for six months. This authorises transactions with Syrian governing institutions for essential public services, and for energy supplies for humanitarian purposes, and allows non-commercial personal remittances sent to individuals in Syria.
The UK followed the American example only on the 12th of February, issuing General Licence INT/2025/5810196 to allow for payments to be made, “necessary to provide humanitarian assistance, other activities that support basic human needs and facilitate the timely provision of those activities in Syria.”
On the 13th of February, Stephen Doughty, Minister of State in the Foreign Office, promised in a written statement to the House of Commons that more was on the way, “in the coming months,” including amendments to the Syria Regulations, “which Members of Parliament will have the opportunity to debate.”
Then on the 24th of February, the EU announced the suspension of some restrictions in the areas of energy and transport, finance and banking. The UK followed this move by lifting asset freezes on twenty-four entities, including the Central Bank of Syria, Syrian Arab Airlines, and energy companies.
“The Europeans have taken steps on sanctions slightly in advance of us,” Hamish Falconer admitted to the House of Commons on March 10th, “they relaxed their sanctions before we did.” Mr Falconer is the Parliamentary Under-Secretary of State at the Foreign Office responsible for the Middle East.
Understanding sanctions
To understand more, we spoke to Eyad Hamid of the
Syrian Legal Development Programme, and Vittorio Maresca di Serracapriola of Karam Shaar Advisory. SLDP is a legal NGO with a particular focus on human rights and business, while Karam Shaar Advisory Ltd works on political economic issues, and publishes a monthly economic bulletin called
Syria in Figures. Both organisations have done extensive work on Syria sanctions.
So to begin with, which sanctions are we talking about? Not sanctions against individuals, the asset freezes and travel bans imposed on particular members of the Assad regime. Nor do we mean the UN Security Council sanctions against designated terror organisations, ISIS, Al-Qaeda, and Hayat Tahrir al-Sham. And we’re not talking about arms sanctions, sanctions related to chemical weapons, or sanctions on dual-use goods and technology.
We’re talking about sanctions targeting whole sectors of the Syrian economy: Prohibitions applying to investments; Sanctions on the oil and gas sector; Sanctions on air transport; Sanctions on luxury goods; And even sanctions on electricity production.
While measures against individuals, or organisations, or even against categories of weapons, can be termed targeted sanctions, these sectoral sanctions are indiscriminate in their effects.
“The Europeans have taken steps on sanctions slightly in advance of us”
Hamish Falconer MP, Parliamentary Under-Secretary of State at the Foreign Office.
“Ideally, the UK should be lifting all of its sectoral sanctions against Syria,” Eyad Hamid says. “The fall of the Assad regime renders the current sanctions regulations unjustifiable.”
Not only would it be unjust, but “it would be a violation of international law” for Western countries to keep these sanctions in place, Vittorio Maresca di Serracapriola argues. “These sanctions were imposed for the crimes of a bygone regime, so they should not outlive it.”
Years of destruction and forced displacement, of criminality and corruption, and of international isolation have impoverished the country. Already in 2023, the World Food Programme was reporting that fifty-five percent of the population, almost thirteen million people, were food insecure, of which more than three million were severely food insecure, while the UN relief chief warned that ninety percent of the population was living below the poverty line.
As a bare minimum, sanctions should be lifted against the electricity, oil and banking sectors, Eyad says. Mains electricity is now available only two or three hours a day, and is needed not only in homes, but also for water supplies, for industrial production, for hospitals, and schools.
The UK’s Syria sanctions regulations impose trade prohibitions on goods and technology relating to electricity production, services relating to the construction and installation in Syria of new power plants for electricity production, and on goods and technology relating to crude oil and natural gas.
And while the UK has now lifted asset freezes on several Syrian oil companies, the regulations still impose prohibitions on investments in these areas, including granting a loan or credit, acquiring any ownership interest in or creating a joint venture with a person connected with Syria who is engaged in the exploration, production or refining of crude oil or the construction or installation of a new power plant for electricity.
As with electricity, oil is also essential for industrial production, transportation, heating and more. “The Assad regime had Iranian and Russian support on this front,” Eyad points out, but now sanctions hinder energy deliveries from allied countries.
On banking, in order to supply Syria with affordable goods, licit financial channels need to be available to the import-export trade, Eyad points out. And diaspora Syrians also need easier and safer ways to send remittances. British Syrians, for example, need to be protected from the dangers of illicit money transfer channels.
Again, the UK has now lifted asset freezes on a number of banks, including the Central Bank of Syria, but prohibitions remain. In short, UK credit or financial institutions are prohibited from doing business with Syrian credit or financial institutions. There are also prohibitions on trading in public bonds or public-guaranteed bonds.
Vittorio says that this issue, the impossibility of accessing international financial channels, comes up a lot in his contacts with Syrian civil society, for individuals, organisations, and business. Industry is struggling, and as a result, it’s impossible to increase living standards, “precisely because of these sectoral sanctions,” he tells us. “Most importantly, the banking sector ones, because these capital inflows that would come from countries that used to invest in Syria, it’s now impossible for them to access the country. Syria is cut off completely from the global map of financial transactions.”
And because these banking sector sanctions create a phenomenon called de-risking, they don’t only affect commercial businesses. “Also inflows related to charity donations, and in general money flowing for aid purposes, it is really difficult for the Syrian people to receive them because of these sectoral sanctions, because a lot of banks will be unable to process them,” Vittorio explains.
“Syrians need to see real changes in their lives”
Eyad Hamid, Syrian Legal Development Programme.
When Parliament discussed the recent sectarian violence in Syria on March 10th, some MPs questioned the Government’s criteria on lifting sanctions, asking whether the violence changed Government’s assessment of the merits of lifting sanctions. Members of Parliament will continue to have concerns about Syria’s new government, about its inclusiveness, about its accountability. Are these concerns justified, we asked Eyad and Vittorio? And should they make Parliament cautious about lifting sanctions?
While the new government has been sending some of the right signals, it will take time to judge their actions, Eyad considers. “Syrian people’s lives do not have this luxury,” he says. “Syrians need to see real changes in their lives compared to life under Assad, to maintain hope for a better future, and even strengthen their will in the face of authoritarianism, if this case materialises.”
There are different types of sanctions, Vittorio reminds us. “There are ones to target the Assad regime, and ones that are UN-mandated and target al Qaeda, and Jabhat al Nusra, and Ahrar al Sham, and all these groups.” And Hayat Tahrir al-Sham, the armed group led by Syria’s new interim president Ahmed al-Sharaa, is included in these. “Actually, these sanctions that are affecting the new administration and its members, including the now de facto president, are to some extent even stronger, in the sense that they are UN mandated. So every UN member state has to implement them.”
So, could one take the existence of the UN sanctions against Hayat Tahrir al-Sham as an argument for being more relaxed about lifting the sectoral sanctions, we ask? “Yes, arguably so,” Vittorio replies. “But I think the main argument about relaxing the sectoral sanctions is that sanctions always serve a purpose, right? They’re always implemented with a specific rationale, that is public. These sanctions were placed to target the Assad regime. Their rationale for being in place is gone.”
What alternative instruments to sanctions might the UK use to address concerns about the new Syrian government, we ask? There are two main ways to go about this, Eyad suggests. The first is to keep open channels with the new government. Unlike the Assad regime, the new government is engaging with everyone to start a new page in Syria’s diplomacy, and this is an opportunity not to be ignored. The other way is to strengthen civil society and the media to be the real check in the face of any government. “This remains difficult to achieve during economic difficulties, for which sanctions are partly to blame,” Eyad points out.
Beyond lifting UK sanctions
Beyond the lifting of sectoral sanctions, what would international investors need to see, in order to do business in Syria? “First of all, very obviously, peace,” Vittorio Maresca di Serracapriola tells us. “And that depends on an inclusive administration, and a process of transitional justice that works well. This is a necessary condition for private investors to have confidence in Syria.”
Another important hurdle is compliance with international standards on anti-money laundering and counter financing of terrorism practices. “Syria is on the grey list of the Financial Action Task Force,” Virrorio points out. “Actually, I think Syria was placed on the grey list in 2010, so before economic and sectoral sanctions were created against the Assad regime. All the issues regarding money laundering and the presence of terrorism financing in the country would also need to be tackled to attract foreign investors.”
And Syria will need large investments from the private sector, given the conditions of state institutions, Eyad Hamid points out. The new government also promised a wide privatisation programme to support improving services. “The main concern in this scenario is infringing on Syrian’s human rights in an economic reconstruction process that ignores the violations that took place over the past fourteen years,” Eyad says. “Any endeavour, private or otherwise, must be sensitive to the country’s and people’s conditions.” A Human Rights Due Diligence process can help investors to navigate this area. “HRDD allows businesses to understand the context where they operate and implement measures to address these risks.”
And if the sectoral sanctions are fully lifted, what is the potential for Syria’s economic future? “I think the potential is huge,” Vittorio says. “The Syrian people are rich in terms of human capital. A lot of the Syrian diaspora has expressed its willingness to go back to Syria and help rebuild. And Syria has a history of sound economic resilience, so there is potential for industry to get back in shape. But of course, it depends on the stability of this transition, which is hard to predict.”
“The Syrian people are rich in terms of human capital”
Vittorio Maresca di Serracapriola, Karam Shaar Advisory
Located between Turkey, Lebanon, Iraq, and Jordan, and linking the Mediterranean and the Euphrates, trade has been central to Syria’s history for millennia. Now with the fall of Assad and the expulsion of Iranian forces, there is hope that Syria can again benefit from peaceful trade with its neighbours.
Amongst those neighbours, Turkey is the main foreign power backing Syria’s new government, Vittorio points out. “Turkey definitely will try to push its own economic interest, and maybe the current administration will benefit from that,” he says. The Turkish government has already for some years been investing in those parts of northern Syria where its military forces have been positioned.
During the war, Syria’s strategic location was a key motivation for intervening states, particularly Iran, which valued Assad’s Syria as its military supply route to Hezbollah in Lebanon. “Most of the supplies of Hezbollah were coming through Syria, through the al-Qusayr and Homs route, also through the Latakia port, which is just right above Tripoli in Lebanon,” Vittorio explains.
“But now that Syria has, let’s say, disaffiliated itself from the so-called axis of resistance, and Lebanon itself now has an administration that is backed by Washington, there is great momentum for both economies to work in synchrony,” Vittorio believes. “And especially for the banking sector, because, again, the banking sector in both countries has been historically very important. A lot of Lebanese banks have ties to Syrian banks and vice versa. So, there’s definitely a lot of potential.”
That potential depends on sanctions being lifted, and not just UK sanctions. In his January evidence to the Foreign Affairs Committee, Simon Collis pointed to an extra difficulty, as US sanctions don’t just prevent US entities doing business with Syria, they can bring penalties upon any party anywhere in the world doing business with Syria. “Even if the European and UK sanctions are lifted, because of the extraterritorial element of American sanctions, companies will still hesitate to trade or do business,” he explained. “For the Government here, in thinking what they can do about Syria, conversations with Washington about this will be important,” he said.
“It is time to be bold. There is nothing to lose from being bold, dropping the sanctions, reopening the embassy… doing more, more quickly, along the lines that are already happening.”
Illustrations by
Lucinda Rogers.
Notes
Syrian Legal Development Programme
https://sldp.ngo/
Karam Shaar Advisory Ltd
https://www.karamshaar.com
Commons Foreign Affairs Committee, session on the situation in Syria, 28 January 2025
https://committees.parliament.uk/event/23136/formal-meeting-oral-evidence-session/
Statement on Syria, House of Commons, 10 March 2025
https://hansard.parliament.uk/commons/2025-03-10/debates/B757635E-697A-4B9F-A6E7-6B8E7E35F97D/Syria
Syria sanctions: guidance
https://www.gov.uk/government/publications/syria-sanctions-guidance/syria-sanctions-guidance#
US Treasury Issues Additional Sanctions Relief for Syrian People, 6 January 2025
https://home.treasury.gov/news/press-releases/jy2770
OFSI General licence INT/2025/5810196, 12 February 2025
https://www.gov.uk/government/publications/ofsi-general-licence-int20255810196
Syria: EU suspends restrictive measures on key economic sectors, 24 February 2025
https://www.consilium.europa.eu/en/press/press-releases/2025/02/24/syria-eu-suspends-restrictive-measures-on-key-economic-sectors/
Update on Syria: Lifting asset freezes on 24 entities, 6 March 2025
https://www.gov.uk/government/news/update-on-syria-lifting-asset-freezes-on-24-entities
PDF
https://assets.publishing.service.gov.uk/media/67c96f7775d7505462fc660d/Notice_Syria_060325.pdf
