The United States and European Union upended the Syria sanctions landscape over the past few months, ending their broad longtime sanctions on the country’s economy while maintaining restrictions on the networks of the former Bashar al-Assad regime.
Both jurisdictions said their rollbacks would support Syria’s efforts to “rebuild” following the end of its civil war. But the individuals and companies that were embedded for years in Assad’s networks will continue to present sanctions-exposure risks, even outside of a reopening Syria.
For international businesses looking to invest in the country’s redevelopment, the end of its across-the-board sanctions will require a more nuanced approach.
In the same statement, Treasury said it was re-designating 139 individuals and entities “affiliated with the previous regime” under different sanctions authorities. Those included former Assad officials and associates, facilitators of the old regime, and companies of the sanctioned individuals.
On the EU side: The EU, meanwhile, lifted in May “all economic restrictive measures on Syria, with the exception of those based on security grounds.” It also lifted asset freezes on 24 entities, including the Central Bank of Syria and companies involved in oil production and refinement, while extending its designations of Assad-tied individuals and entities until June 1, 2026.
What that means: Anyone looking to enter into Syria’s economy must deal with the realities of sanctions measures that remain in place. That will require screening counterparties against two partially overlapping sanctions lists that continue to target individuals and entities that Washington and Brussels say “materially threaten the peace, stability and security of Syria.”
One factor to consider beyond sanctions: Some companies that were long tied to Assad now appear to be making inroads with the new government. A close relationship with Syria’s new leaders might signal a stabler partner.
For example: Consider Marota City, a multimillion-dollar luxury project on expropriated land on the outskirts of Damascus. The project and investment companies involved in its development have long personified the crony networks of the Assad regime during Syria’s civil war.
But the development has remained active since Assad’s overthrow, continuing to advertise real estate plots as of this month.
Many important actors in this development were a part of the U.S. government’s delisting, including Bunyan Damascus PJSC, Damascus Cham Holding Company and Rawafed Damascus PJSC. All three remain sanctioned by the EU.
Both jurisdictions said their rollbacks would support Syria’s efforts to “rebuild” following the end of its civil war. But the individuals and companies that were embedded for years in Assad’s networks will continue to present sanctions-exposure risks, even outside of a reopening Syria.
For international businesses looking to invest in the country’s redevelopment, the end of its across-the-board sanctions will require a more nuanced approach.
What changed—and what didn’t
On the U.S. side: The Treasury Department announced in late June that it had lifted sanctions on 518 individuals and entities designated under the Syria sanctions program, including those “critical to Syria’s development, the operation of its government, and the rebuilding of the country’s social fabric.”In the same statement, Treasury said it was re-designating 139 individuals and entities “affiliated with the previous regime” under different sanctions authorities. Those included former Assad officials and associates, facilitators of the old regime, and companies of the sanctioned individuals.
On the EU side: The EU, meanwhile, lifted in May “all economic restrictive measures on Syria, with the exception of those based on security grounds.” It also lifted asset freezes on 24 entities, including the Central Bank of Syria and companies involved in oil production and refinement, while extending its designations of Assad-tied individuals and entities until June 1, 2026.
What that means: Anyone looking to enter into Syria’s economy must deal with the realities of sanctions measures that remain in place. That will require screening counterparties against two partially overlapping sanctions lists that continue to target individuals and entities that Washington and Brussels say “materially threaten the peace, stability and security of Syria.”
- Perhaps nowhere is that more vital than in Syria’s revived real estate and construction sectors.
A real estate revival, with risk pockets
Construction and property development are expected to pull in the first waves of foreign capital, but the sectors demonstrate a U.S.-EU disconnect: While the U.S. has delisted many such Syrian companies, the EU has maintained sanctions on many of the same actors.One factor to consider beyond sanctions: Some companies that were long tied to Assad now appear to be making inroads with the new government. A close relationship with Syria’s new leaders might signal a stabler partner.
For example: Consider Marota City, a multimillion-dollar luxury project on expropriated land on the outskirts of Damascus. The project and investment companies involved in its development have long personified the crony networks of the Assad regime during Syria’s civil war.
But the development has remained active since Assad’s overthrow, continuing to advertise real estate plots as of this month.
Many important actors in this development were a part of the U.S. government’s delisting, including Bunyan Damascus PJSC, Damascus Cham Holding Company and Rawafed Damascus PJSC. All three remain sanctioned by the EU.
Damascus Cham was launched under the Assad regime in 2016 and is wholly owned by the Governorate of Damascus. But in April, in an apparent sign of its evolution and legitimacy in the eyes of the new government, Marota City and Damascus Cham hosted the newly installed governor of Damascus, Maher Marwan, who promised to respect the rights of property holders, a nod to continuing legal disputes over wartime land seizures.
Case study 1: Lina al-Kinayeh, delisted by the U.S. in June, was sanctioned in 2020 for serving as a senior government official, including heading the office of then-first lady Asma al-Assad. (Asma al-Assad remains sanctioned.)
But Kinayeh has a much closer ongoing connection to another sanctioned actor: her husband, Mohammed Hammam Mohammed Adnan Masouti, a prominent regime businessman and former senior parliament official, whom the U.S. simultaneously re-designated under the updated Syria executive order.
Delisted but not derisked
Several individuals and entities removed from the U.S. sanctions list retain close family or commercial links to actors who are still under sanctions, raising the prospect of secondary exposure—even outside of Syria’s borders.Case study 1: Lina al-Kinayeh, delisted by the U.S. in June, was sanctioned in 2020 for serving as a senior government official, including heading the office of then-first lady Asma al-Assad. (Asma al-Assad remains sanctioned.)
But Kinayeh has a much closer ongoing connection to another sanctioned actor: her husband, Mohammed Hammam Mohammed Adnan Masouti, a prominent regime businessman and former senior parliament official, whom the U.S. simultaneously re-designated under the updated Syria executive order.
It’s unclear whether Kinayeh will stay in Syria now. A March report by the French newspaper Le Figaro stated that Kinayeh had briefly fled to Beirut a few days after Assad’s fall, later returning to work for the new government in an unspecified capacity, before it dismissed her. Her assets in Syria were later confiscated, according to the report.
Case study 2: The U.S. also delisted Adib Muhanna, despite his work for years as a fixer for the Syrian tycoon Rami Makhlouf, whom the U.S., EU and U.K. all have kept under sanctions.
Muhanna held senior posts across Makhlouf’s micro-finance and telecom ventures until at least 2021. Those who remain in Makhlouf’s circle today would present risks of facilitating sanctions evasion on his behalf.
The bottom line: The sweeping U.S. and EU rollbacks transform Syria from a blanket “no-go” market into a cautiously re-opened frontier, but they do not erase risk. Hundreds of Assad-era power brokers and businesses remain under sanctions, and several newly delisted figures still orbit sanctioned networks.
For banks, investors and would-be contractors, that means opportunity is laced with potential tripwires. Capital and investment can begin flowing into Syria again, but private industry should be prepared for policy snapbacks and lingering exposure.
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Case study 2: The U.S. also delisted Adib Muhanna, despite his work for years as a fixer for the Syrian tycoon Rami Makhlouf, whom the U.S., EU and U.K. all have kept under sanctions.
Muhanna held senior posts across Makhlouf’s micro-finance and telecom ventures until at least 2021. Those who remain in Makhlouf’s circle today would present risks of facilitating sanctions evasion on his behalf.
The bottom line: The sweeping U.S. and EU rollbacks transform Syria from a blanket “no-go” market into a cautiously re-opened frontier, but they do not erase risk. Hundreds of Assad-era power brokers and businesses remain under sanctions, and several newly delisted figures still orbit sanctioned networks.
For banks, investors and would-be contractors, that means opportunity is laced with potential tripwires. Capital and investment can begin flowing into Syria again, but private industry should be prepared for policy snapbacks and lingering exposure.
More from the Kharon Brief:
