No clear roadmap
Trump’s announcement and Secretary of State Rubio’s subsequent statement still offered no clear roadmap for unwinding sanctions layered under multiple authorities. Reuters reported that State and Treasury officials initially received no White House guidance, leaving uncertainty about whether Trump meant lifting or suspending EO 13582’s asset freezes; selectively waiving sanctions in part or suspending Caesar Act in total; easing the Syria Accountability Act’s expansive export prohibitions, or even tackling the State Sponsor of Terrorism designation.
The latter requires Congressional notification 45 days in advance and certification that Syria has ceased terrorism support for six months or undergone a fundamental government change—a tall order given al-Sharaa’s ties to Hay’at Tahrir al-Sham (HTS)—a designated terrorist organisation since 2018.
Additional terrorism sanctions complicate matters further, as many of the Syrian governing authorities are Foreign Terrorist Organisations and Specially Designated Global Terrorists like Ansar al-Islam, Islamic Jihad Union, Katibat Imam al-Bukhari, Katibat al-Tawhid wal-Jihad, and Liwa al-Muhajireen wal-Ansar.
This raises concerns that Syria’s new government could be seen as a reconstituted FTO, risking further sanctions. Without legal clarity distinguishing HTS and these organisations from the Syrian government, investors and humanitarian groups face compliance risks.
A laundry list of conditions
President Trump’s 13 May announcement, with a prolonged absence of legal guidance, risks stalling progress, as banks, businesses, and aid groups hesitate to engage without defined boundaries. During his Gulf trip, Trump outlined requests of the Syrian government that can be tied to sanctions removal, including normalising ties with Israel, expelling foreign terrorist groups, deporting Palestinian militants, and aiding US efforts against Islamic State (IS) resurgence.
Earlier in 2025, the State Department reportedly set conditions for partial relief, demanding the elimination of chemical weapons stockpiles, counter-terrorism cooperation, and barring foreign fighters from senior government roles. Importantly, the administration did not rescind or limit General License 23 that authorises transactions related to earthquake relief efforts in Syria to facilitate humanitarian aid, and General License 24 that permits certain transactions with Syrian governing institutions to support essential governance services and public utilities following the fall of Bashar al-Assad.
To realise Trump’s vision, the US must take these measures further and adopt a structured, conditional approach with clear benchmarks, ensuring both the administration and Congress clarify that failure to meet these political reforms—like expelling foreign fighters and holding transparent elections—will slow, halt, or reverse relief through reimposed sanctions and other restrictions.
Beyond these political demands, Syria must pursue significant institutional reforms to rejoin the global economy and earn international trust. This includes measures such as strengthening anti-money laundering (AML) laws and regulations with stringent controls on bulk cash movements to block terror financing, adopting robust transaction reporting, and other measures in compliance with the Financial Action Task Force and other international standards.
These steps would showcase Syria’s commitment to combating illicit finance and fostering a transparent economic framework, paving the way for global market integration. The ball is in al-Sharaa’s court: without delivering on both political and institutional reforms, Syria risks squandering this chance for renewal, as Congress and the administration stand ready to tighten the screws if progress falters.
All eyes on Sharaa
Conversely, if al-Sharaa succeeds in delivering both political and institutional reforms over the long term, Syria could seize this historic opportunity for renewal. The administration can work bilaterally and multilaterally to develop financial inclusion measures, which are vital for Syria’s recovery. Offshore lending facilities in Jordan or the UAE, managed under strict AML and counter-terrorism financing (CTF) protocols, could provide credit to Syrian businesses, transitioning onshore as the banking sector stabilises.
Once legislation pending before Congress passes and is signed into law, a pilot for US dollar-backed stablecoin payments, with fiat conversions outside Syria, could connect small vendors to global markets while complying with international AML/CTF standards. Public-private partnerships and a public registry of government contracts can ensure transparency, preventing SDGTs from profiting.
Al-Assad’s looted wealth also offers a transformative opportunity. Sanctions targeting the Assad family and their facilitators must remain in place to prevent access to blocked assets, requiring targeted revisions to, but not wholesale recission of, the Syria sanctions regulations. In this respect, a multilateral Syria asset recovery task force could seize an estimated $2bn in illicit assets hidden in shell companies. Redirecting these funds to rebuild hospitals, roads, and schools hinges on democratic milestones—either routed through the government if they have achieved certain milestones or through an international mechanism if they have not.
Appointing a senior administration official to coordinate Syria’s sanctions policy would streamline communication across agencies, ensuring clarity and efficiency in implementing relief measures. This role would facilitate rapid dissemination of policy updates to stakeholders, including businesses and allies, while overseeing compliance with reform benchmarks. It would also enable fast-track licensing for export-controlled goods, such as energy equipment critical for reconstruction, once Syria verifies agreed-upon reforms.
Syria stands at a crossroads. Trump’s pledge needs to be transformed into a clear, performance-based roadmap. Syrians, who’ve endured unimaginable hardship, deserve this chance at renewal. Yet, the US must wield sanctions relief as a lever, not a blank cheque, to ensure accountability. Without clarity, Trump’s bold vision risks unravelling, leaving Syria’s fragile hope in limbo.