Questions from the compliance floor after OFAC's August 2026 Syria relief measures.
Understanding the Compliance Challenges
With the State Department's removal of Syria from the State Sponsor of Terrorism list on August 24, 2026, compliance teams face the task of updating screening protocols, reassessing customer relationships, and interpreting what "relief" means when list-based sanctions still apply. These questions arise from real conversations with compliance officers, sanctions analysts, and BSA officers who are translating policy changes into operational decisions. Some answers are straightforward, while others require balancing two realities: Syria is no longer an SST, but your screening obligations remain.
Q1: Do You Still Need to Screen Syrian Counterparties?
Yes, you do.
The SST rescission removed Syria from the Terrorism List Governments Sanctions Regulations (31 CFR Part 596), but it didn't clear the SDN List. Bashar al-Assad and his associates, human rights abusers, Captagon traffickers, and affiliates of ISIS and al-Qa'ida remain designated. Iran-linked proxies in Syria are also still blocked.
Your name screening process must catch these individuals and entities. While you can generally transact with Syria, you can't transact with everyone in Syria. You're still required to block property and reject transactions involving designated persons under Executive Order 13224, as amended, and other authorities.
Update your screening rules to reflect the new environment, but don't turn off Syrian screening entirely. Focus on specific names, not a blanket country block.
Q2: What Happened to General License 25?
OFAC revoked GL 25 on August 24, 2026, the same day HTS was removed from the SDN List.
GL 25 had authorized certain transactions that might have been prohibited because HTS held positions in the Syrian government. Once HTS was delisted, OFAC deemed the authorization unnecessary. If your team relied on GL 25 for Syria-related activities, update internal authorizations, compliance memos, and counterparty records.
Remember, the revocation doesn't authorize new activity. It just removes a license you no longer need for HTS-related transactions. If your transaction involves other blocked persons still on the SDN List, you can't proceed without separate authorization. Don't treat GL 25's revocation as a green light beyond what the HTS delisting permits.
Q3: Can You Onboard Syrian Customers Now?
You can consider it, but your Customer Due Diligence process must account for elevated risk.
Syria is no longer subject to comprehensive sanctions, so you're not automatically prohibited from opening accounts for Syrian nationals or entities. However, your risk-based approach should flag Syria as a jurisdiction with significant residual sanctions risk, weak AML/CFT infrastructure, and ongoing conflict-related financial crime concerns.
Enhanced due diligence is necessary:
- Identify beneficial ownership for Syrian entities, with scrutiny on government or military connections.
- Verify the source of funds, especially for wealth accumulated during the conflict.
- Conduct ongoing due diligence with more frequent reviews than usual.
- Calibrate transaction monitoring rules to detect sanctions evasion, trade-based money laundering, and Captagon trafficking.
Don't onboard Syrian customers just because you can. Onboard them when you can manage the risk and explain your decision to examiners.
Q4: Can You Bank Former HTS Members?
Legally, yes. Practically, consider reputational risk and residual terrorism financing concerns.
Treasury confirmed that US persons don't need OFAC authorization to engage in transactions with HTS, provided those activities don't involve other blocked persons. But HTS's delisting doesn't erase its history. It was designated as a Specially Designated Global Terrorist for years. Some former affiliates remain designated, such as Sa'd Bin Sa'd Muhammad Shariyan al-Ka'bi and Jamal Husayn Zayniyah, who were designated on the same day HTS was delisted.
If evaluating a customer with HTS ties, your enhanced due diligence should include:
- Verification that the individual isn't one of the redesignated affiliates.
- Assessment of whether they've genuinely disengaged from terrorist activity or still maintain connections to designated groups.
- Documentation of your risk decision, as examiners and auditors will ask.
This isn't a legal prohibition. It's a risk management judgment. Some institutions may decide the reputational exposure isn't worth it, even if OFAC permits it.
Q5: What About Export Controls?
The August 24, 2026 Tri-Seal Advisory confirms that the Secretary of State waived the Syria Accountability Act's prohibition on exporting items on the US Munitions List to Syria. The Secretary also waived remaining Chemical and Biological Weapons Control and Warfare Elimination Act restrictions, including limits on Arms Export Control Act sales and foreign military financing. That waiver takes effect 20 days after Congress was notified.
Operationally, the Department of Commerce expects to relax Syria-related restrictions in the Export Administration Regulations, and the State Department plans to amend the International Traffic in Arms Regulations to eliminate the policy of denial for defense articles and services. These amendments aren't published yet.
Until they're published, apply existing licensing requirements. Don't assume relief based on the advisory's forward-looking language. Wait for the regulatory text.
Q6: How Should You Update Your Sanctions Risk Assessment for Syria?
Move Syria from "prohibited jurisdiction" to "high-risk jurisdiction with list-based sanctions."
Your risk assessment should reflect:
- Sanctions risk: Elevated, due to numerous designated persons and entities remaining on the SDN List.
- AML/CFT risk: High, given years of conflict, weak regulatory infrastructure, and limited financial transparency.
- Proliferation financing risk: Moderate to high, considering Syria's past proliferation activities and ongoing regional instability.
- Terrorist financing risk: High, with ISIS and al-Qa'ida affiliates still operating in parts of the country.
Your transaction monitoring rules should include scenarios for:
- Payments involving designated Syrian persons.
- Trade finance structures that could facilitate sanctions evasion or reconstruction-related corruption.
- Remittances that could support terrorist financing or proliferation networks.
Update your customer risk rating model to treat Syrian nexus as a risk factor, not an automatic prohibition. This is a meaningful shift from the SST era, but it's not a free pass.
Where to Go for More
OFAC's updated FAQs 1220, 1221, and 1222 reflect the SST rescission, the HTS delisting, and the GL 25 revocation. FAQ 1223 was removed. The August 24, 2026 Tri-Seal Advisory from Commerce, State, and Treasury provides the most comprehensive overview of current Syria relief measures.
For export controls, monitor the Bureau of Industry and Security and the Directorate of Defense Trade Controls for the anticipated regulatory amendments. Until those are published, existing licensing requirements remain in effect.
If you're evaluating Syria-related business, document your risk decision thoroughly. The policy environment is shifting, but examiner expectations around sanctions compliance and terrorist financing controls haven't changed. You need to show you understood the residual risk and built controls to manage it.
