Go read the guidance document for all the links and detail if you want to know more…

Background

Interest from UK businesses in operating within Syria has grown recently, prompting the UK government to clarify the legal and policy landscape. The government supports UK businesses investing and trading in Syria, provided they follow UK laws and the activity is actually destined for Syria. However, businesses must assess their own risks, particularly regarding bad actors who might try to exploit the situation or use deceptive tactics to bypass rules.

The political situation in Syria has shifted significantly. Following the fall of the Assad regime in December 2024, the UK government removed many sanctions in April 2025 to aid recovery. Further steps toward normalization occurred in late 2025: the UK removed Hay’at Tahrir Al-Sham (HTS) from its list of banned terrorist organizations in October, and in November, the UK removed the Syrian President and Interior Minister from the specific ISIL/Al-Qaida sanctions list. While Syria remains a high-risk environment, the new government is working toward stability, and there are potential commercial opportunities in this lower middle-income market.

What has (and hasn’t) changed

Significant changes to the UK’s Syria sanctions rules took effect on April 24, 2025. To help the Syrian people rebuild, the UK lifted bans on trade, finance, aviation, and energy production. Financial freezes were also removed from entities previously controlled by the Assad regime, such as the Central Bank of Syria, government ministries, and energy or media companies. The current Government of Syria itself is not subject to sanctions.

Despite these relaxations, strict prohibitions remain in place to hold specific individuals accountable. You still cannot do business with people or entities subject to asset freezes. There are also continued bans on exporting chemical and biological weapons technology, goods used for internal repression or spying, and military equipment. Specific trade restrictions apply to the “Governing Authority of Syria”—which includes the transitional authorities and the Central Bank—regarding gold, precious metals, and diamonds. Luxury goods also cannot be sent to Syria. If you are a specific type of regulated firm, you have a legal duty to report suspected sanctions breaches.

UN counter-terrorism sanctions

Separate from the UK’s own rules, the United Nations maintains a counter-terrorism sanctions list (the ISIL/Al-Qaida regime) that still affects business in Syria. While the UK has removed the Syrian President and Interior Minister from its version of this list, other individuals and groups remain designated. Notably, while the UK has de-listed HTS domestically, HTS remains on the UN sanctions list.

The Government of Syria is not on this UN list, meaning interactions with the government generally do not violate these sanctions. However, strict asset freezes and bans on military goods apply to anyone who is on the UN list. This prohibits providing funds or economic resources to them directly or indirectly. Limited exceptions exist, primarily to allow for the payment of basic expenses, but these usually require a licence.

Relevant UK counter-terrorism laws

Under UK law, the Terrorism Act 2000 defines which organizations are “proscribed” (banned). As of October 2025, HTS is no longer a proscribed organization, meaning membership or support for it is no longer a criminal offense in the UK. However, the group Da’esh (ISIL/ISIS) remains banned and poses a threat.

The government aims to ensure that counter-terrorism laws do not stop legitimate humanitarian work. The Crown Prosecution Service (CPS) has guidance stating that prosecuting genuine aid organizations is generally not in the public interest. Additionally, the law offers specific protections: there is a legal defense for “genuinely benign” meetings with banned groups (such as for delivering aid), and organizations can apply to the National Crime Agency for a defense against potential terrorist financing charges for specific transactions.

Humanitarian exceptions and exemptions

Petroleum exceptions

The regulations include a specific rule allowing the use of funds to purchase or supply petroleum products for humanitarian purposes. Since the general ban on petroleum trade was lifted in April 2025, this rule now primarily protects aid organizations if they need to deal with frozen assets to get fuel. If an organization relied on this rule for activities before April 2025, they must notify the government by the end of the year. For activities after April 2025, notification is only needed if the activity would otherwise breach an asset freeze.

General licence

In February 2025, a “General Licence” was issued to facilitate aid. This allows eligible aid organizations (and the banks that serve them) to carry out activities necessary for humanitarian assistance and basic human needs without violating asset freezes. This licence applies to the UK’s independent sanctions but not to the UN sanctions, which have their own separate humanitarian exemption.

Related guidance documents

Businesses and organizations should consult the specific statutory guidance for both the Syria and ISIL/Al-Qaida sanctions regimes to understand the full technical details of prohibitions and licences. A “sanctions hub” on the government website creates a central place to search for all relevant policies.

In addition to sanctions and terrorism laws, other legal frameworks still apply. You must comply with export controls for military and dual-use goods, anti-money laundering regulations, and laws against bribery and corruption. If you are unsure whether your planned activities might break the law—especially given the complexity of the different legal regimes—you should seek independent legal advice.

So, what do you think of this summary? Is it “enough” for you, or are you better served by the guidance document, for a first read?