OFAC removes Syria sanctions regulations

• What changed: The U.S. Treasury’s OFAC issued a final rule removing the Syrian Sanctions Regulations (31 CFR Part 542) from the Code of Federal Regulations, effective August 26, 2025.
• Why it changed: Follows the June 30, 2025 presidential order terminating the Syria national emergency and revoking six Syria-related EOs, effective July 1, 2025. Persons designated solely under the Syria program have been removed from the SDN List and unblocked.
• What still applies: Other authorities (e.g., E.O. 13894 for accountability, counterterrorism programs, Captagon-related designations) still bite; pre-July 1, 2025 violations can still be enforced.

What happened

North Press Agency summarized the policy shift: OFAC removed the Syria Sanctions Regulations after the U.S. ended the Syria national emergency; Syria-only SDNs are being taken off the list and property is unblocked. The final rule took effect on Aug 26, 2025.

Official sources confirm the details: OFAC’s Inactive/Archived Syria page lays out the revocations, SDN removals for Syria-only designees, and the continuing applicability of other authorities; the Federal Register notice formalizes the rule and clarifies that prior conduct remains enforceable.

Think of this as a re-routing, not a green light. The “Syria program” is gone, but other programs (counterterrorism, Captagon, regional accountability) remain fully live — and some entities were re-designated under E.O. 13894.

“Fix by Monday” checklist for Compliance

1. Refresh your lists & logic. Ensure your provider has pulled the Syria-only SDN removals/unblocks and that your sanction-screening logic no longer references the removed Part 542 tags — without downgrading E.O. 13894 and other risk flags.
2. Update risk policy & KYC narratives. Amend your sanctions policy to reflect program removal plus continuing authorities; add language on look-backs for hits tied to pre-July 1, 2025 conduct.
3. Re-calibrate alerting. Expect drops in “Syria-program” false positives; set a temporary QA sample for any newly “unblocked” counterparties to verify no hits under other programs remain.
4. Trade & payments flow review. Unblock flows only where no other sanctions apply; add a control to check Captagon-related, terrorism-related, or regional-accountability listings before release.
5. Board memo. One-pager covering legal basis (EO revocations, effective dates), what changes in screening, and what risks persist — plus a note that legacy violations remain prosecutable.

The legal backbone

• EO package revoked: The June 30 order terminated the Syria national emergency and revoked EOs 13338, 13399, 13460, 13572, 13573, 13582 (effective July 1, 2025). (OFAC)
• Regulations removed: OFAC’s final rule removes 31 CFR Part 542 from the CFR (effective Aug 26, 2025).
• Who’s still restricted: OFAC underscores that other authorities and lists still apply (e.g., E.O. 13894 for accountability; terrorism/illicit-drug frameworks).
• Past conduct still matters: Ending the emergency does not affect actions for conduct before July 1, 2025.

Practical impacts for screening teams

• List deltas: Expect bulk removals of Syria-only SDNs; ensure your delta audit captures who fell off and why, and whether any were re-listed under other authorities.
• Counterparty uplift: Some counterparties may become serviceable again; require enhanced due diligence to confirm no residual flags (terrorism, narcotics, human-rights).
• Metrics: Track alert-rate drift, match-quality, and false-positive reduction over the next 30–60 days; report anomalies tied to “Syria program” removals.

Tools & shortlists

• Start with our Best AML Software Providers for options that handle rapid list churn and program-aware logic.
• For sanctions & adverse-media coverage with API depth, see our ComplyAdvantage review — especially relevant for program transitions and rule re-weights.
• If your onboarding stack feeds sanctions decisions, our KYCAID review shows how to keep KYC → AML signals consistent when lists shift.

Talking points for your next executive huddle

• This is not blanket “de-risking”. The Syria program is gone; counterterrorism/Captagon/accountability programs continue. Validate gaps before unblocking.
• Expect remediation asks. Regulators will ask how you updated lists, rules, training, and QA to reflect the change — keep an audit trail.
• Legacy exposure remains. Violations tied to pre-July 1, 2025 conduct stay enforceable. Don’t erase historical casework.