Vittorio Maresca di Serracapriola and Karam Shaar
Targeted sanctions—i.e., the listing of specific persons or entities—are often seen as the precision-guided munitions of economic statecraft. Yet despite their narrow design, they can trigger unintended systemic effects, particularly in contexts like Syria where sanctioned actors control core economic sectors. In such cases, targeting an individual or entity may effectively cripple an entire sector, even without a formal sectoral measure. This reveals a contradiction at the heart of the EU’s current sanctions regime: while sectoral sanctions have been lifted to enable reconstruction, targeted sanctions continue to obstruct the very actors and transactions needed to achieve it. Without a more sophisticated approach—one that accounts for the real-world entanglements between sanctioned entities and the process of economic recovery—the intended benefits of sanctions relief may be neutralized before they can take effect. This report proposes a methodology for determining whether to lift or maintain EU targeted sanctions on Syria.
By the 1990s, the negative externalities of comprehensive trade and financial sanctions had become increasingly difficult to ignore. In response, a growing coalition of scholars, civil society groups, policymakers, and affected communities began advocating for targeted sanctions—policy instruments designed to hurt elite supporters while sparing the general population. Described as the precision-guided munitions of economic statecraft, these measures seek to alter the incentives of powerful persons and entities, encouraging internal pressure on the government without disrupting broader economic life. Unlike blanket embargoes, targeted sanctions focus on specific persons and entities deemed responsible for state abuses, war crimes, or illicit activities, typically through asset freezes, travel bans, and restrictions on economic transactions with designated persons and entities. By isolating these targets, policymakers aim to exert pressure with maximum impact and minimum collateral damage.
Yet the practical effects of targeted sanctions are not always so contained. An established concern is that these measures, though narrow by design, may produce unintended systemic effects—particularly in contexts like Syria where sanctioned persons and entities dominate critical sectors. When a person is targeted, they are largely blocked from engaging in financial and economic relationships with actors from the sanctioning countries. This, in turn, can disrupt the person’s associated financial and economic activities. In such cases, targeting a person or entity may effectively cripple an entire sector, regardless of formal sectoral restrictions. This blurs the distinction between targeted and sectoral sanctions. It also calls into question the assumption that targeted measures can avoid the economic disruption associated with comprehensive sanctions.
These risks are further compounded by patterns of overcompliance. Fearful of regulatory ambiguity, reputational harm, or exposure to secondary sanctions, international businesses and service providers may choose to disengage entirely from the Syrian economy, even if the transactions are legally permitted. Such risk-averse behavior not only undermines the humanitarian exemptions embedded in various sanctions regimes across different jurisdictions; it may also frustrate the recent easing measures introduced by the European Union (EU) and the United Kingdom (UK) in February and March 2025. While these dynamics apply across multiple sanctions regimes, this paper focuses specifically on the EU’s restrictive measures against Syria.
The disconnect between recent easing measures and ongoing restrictions reveals a fundamental contradiction in the EU’s sanctions framework. Although sectoral sanctions have been lifted to facilitate reconstruction, targeted sanctions continue to block key actors and transactions essential to that process. Where monopolistic or state-linked entities dominate entire sectors, the continued application of targeted sanctions may have effects far beyond their formal scope. In the absence of a more sophisticated approach—one that considers the real-world entanglements between sanctioned persons and entities and economic recovery—the intended benefits of sanctions relief may be neutralized before they can take effect.
Since 2011, the EU has progressively expanded its sanctions regime on Syria. Initially designed to target persons responsible for violent repression, the measures evolved into a web of restrictions with broad systemic impacts—particularly given Syria’s economy, where key sectors are dominated by state institutions, regime elites, and loyalist businesses.
The EU first expressed deep concern over the situation in Syria on 22 March 2011 and condemned the regime’s violent crackdown on civilians. In response to the escalating violence, the EU Council—the institution responsible for defining the EU’s general political direction—1 decided on 9 May 2011 to impose restrictive measures against Syria and those responsible for the violence. The initial sanctions included:
As the conflict escalated into full-scale civil war by late 2011, the EU imposed its first major sectoral measure on 2 September 2011: a ban on the purchase, import, and transport of Syrian crude oil and oil products to the EU. This action responded to the regime’s heavy reliance on oil revenues. While still technically distinct from targeted (known in the EU as “individual”2) sanctions, this step marked the beginning of a hybrid approach that combined targeted sanctions with sector-wide restrictions.
In the following years, the EU introduced additional sanctions with sector-wide objectives. These included:
Key institutions such as the Syrian Central Bank, Syrian Arab Airlines, and large state-owned oil and commodities companies were hit by targeted sanctions, effectively hurting broad segments of the economy. In December 2011, the EU formally expanded its measures to target the oil and banking sectors. A year later, on 29 November 2012, it widened these measures to include the energy, precious metals, luxury goods, and transport sectors.
Further targeting strategic resources, in December 2014, the EU introduced Council Regulation 1323/2014, banning the supply of jet fuel to Syria from EU territories, regardless of the fuel’s origin. The restriction responded to reports that jet fuel was being used in indiscriminate air attacks on civilians. In 2016, Russian tankers began smuggling jet fuel to Syria through EU waters in defiance of the ban, with deliveries routed via Cyprus. The operation involved intermediaries in several countries, including Denmark.
As the conflict persisted, EU sanctions evolved in response to shifting tactics and actors. The focus expanded from senior regime officials and military and intelligence leaders to those who enabled Assad’s war effort or benefited from his patronage networks.
Alongside its Syria-specific designations under Regulation 36/2012, the EU also sanctioned Syrian persons under broader thematic regimes. These included the EU Chemical Weapons Sanctions (Council Decision 2018/1544) and the EU Global Human Rights Sanctions Regime (Council Decision 2020/1999). Both frameworks targeted persons involved in chemical weapons use and serious human rights violations, including members of the Syrian military, security services, and associated business elites.
As the civil war grew increasingly international, the EU also sanctioned non-Syrian actors and entities under the EU Syria sanctions regime. It included persons and entities linked to Russia’s Wagner Group, which fought in Syria in support of the Assad regime, as well as those connected to the Iranian Revolutionary Guard Corps. Certain Iran-backed militia leaders and even companies used by Russia to exploit Syrian resources—such as the Russian firm Stroytransgaz, which partnered with Damascus on energy projects—were also designated.
Despite Syria’s worsening humanitarian crisis, the EU maintained its sanctions to continue pressure on the Assad regime, but gradually expanded humanitarian exemptions—particularly after the February 2023 earthquake that struck Syria and Türkiye. In April 2023, the EU launched a major sanctions package targeting the Captagon trade, listing 25 persons—including members of the Assad family—and eight entities. By that point, the EU had sanctioned 322 persons and 81 entities. All persons were subject to asset freezes, travel bans, and a prohibition on making funds or economic resources available to them, either directly or indirectly. Entities were subject to asset freezes and a similar prohibition on providing funds or economic resources, directly or indirectly.
Following years of sanctions amid a worsening crisis, a dramatic shift occurred in December 2024 when a surprise offensive by armed rebel groups led by Hay’at Tahrir al-Sham toppled the Assad regime. This unexpected regime collapse prompted an urgent EU review of its Syria sanctions. On 24 February 2025, the EU lifted multiple sectoral sanctions and delisted a number of banks and state-owned entities, while continuing to sanction Assad-era figures, war criminals, and illicit financial networks.
The February 2025 sanctions revision included:
Although many experts acknowledge that targeted sanctions have evolved toward broader sectoral measures—a trend sometimes called the comprehensivization of sanctions—less attention is paid to how even selective additions of “individuals” (persons or entities) to sanctions lists can, in practice, produce similar systemic effects. In some cases, targeted sanctions end up functioning like sectoral ones.
The EU’s sanctions on Syria exemplify this overlap. Continued designations of key state companies can blunt or even nullify the effect of lifting sector-wide restrictive measures. While targeted measures are narrow by design, they may nonetheless produce unintended systemic effects.
In the oil sector, the EU sanctioned joint ventures in which the General Petroleum Company (GPC) holds a controlling stake, including Al-Furat Petroleum, Deir Ezzor Petroleum, Ebla Petroleum, and Dijla Petroleum. It also designated key actors in the oil supply chain, such as the Mahrukat Company (the national distributor of petroleum products), the Syrian Company for Oil Transport (also known as the Syrian Crude Oil Transportation Company), and the Syrian Petroleum Company.
The formal easing of sectoral restrictions has had little operational impact due to the continued designation of key sectoral entities. Even after the EU suspended its oil import ban in February 2025, Syrian oil remains effectively off-limits because principal actors like the GPC remain sanctioned. While European companies are theoretically permitted to purchase Syrian oil, any transaction involving the GPC or its subsidiaries would violate sanctions, as EU law continues to prohibit providing funds to listed entities.
Since the GPC serves as the national partner for all oil operations, no deal can proceed without its involvement. Similarly, the Syria Trading Oil Company (Sytrol) acts as the gatekeeper for all oil exports, meaning any export transaction necessarily involves a sanctioned entity. Consequently, the EU’s continued designation of these entities keeps the oil sector effectively closed to European investment and trade despite the formal lifting of the sectoral ban on oil.
Phosphates, another key Syrian export, face a similar situation. Although the EU never formally banned phosphate imports, it designated the sector’s dominant actors: Russian oligarch Gennady Timchenko’s Stroytransgaz, the Syrian state-owned GECOPHAM, and affiliated logistics firms STG-Logistics and STG-Engineering. Because these entities control the entire value chain, any deal involving Syrian phosphates would ultimately benefit a listed entity.
This dominance has pushed European companies into secretive and convoluted trade routes. Investigations show that some firms have continued sourcing Syrian phosphates through front companies and evasive shipping practices—such as turning off ship transponders when loading at Baniyas port. While traders claimed to avoid explicitly listed entities, critics argued that proceeds still flowed to the Assad regime and its allies. As a result, sanctions intended to be targeted have effectively shuttered the phosphate trade and pushed remaining activity underground.
Similarly, even though the EU never imposed sectoral sanctions on agriculture, targeted listings continue to cripple parts of the sector. Once a cornerstone of Syria’s economy, agriculture employed nearly 20% of the pre-war workforce and constituted a direct or indirect economic resource for around 46% of the population. It also accounted for about a third of Syria’s export economy.
Reviving agriculture is essential to the country’s economic recovery. Yet the EU still sanctions the General Organisation of Tobacco, the state monopoly overseeing tobacco cultivation, purchase, and marketing—Syria’s third most important crop. The organization claims that around 60,000 farmers grow tobacco, with some 90,000 people depending on it for their livelihoods. Tobacco also contributes significantly to state revenue and employment.
Cotton, which sits at the intersection of the agriculture and textile sectors, faces the same constraints. The EU sanctioned the Cotton Marketing Organisation, a state-owned firm that monopolizes the ginning and marketing of cotton. As Syria’s second-most strategic crop after wheat, cotton was once central to exports and rural employment. Before the war, Syria ranked among the world’s top producers, with annual output exceeding one million tons—around 8% of global production. Domestic consumption absorbed only a third of the harvest; the rest was exported. The sector supported tens of thousands of jobs, from farming to textile manufacturing. By sanctioning the organization at the heart of this value chain, the EU has effectively frozen the entire sector.
Sanctions on Syria’s banking sector have an even broader reach. The EU maintains restrictions on the Commercial Bank of Syria, the Syrian Lebanese Commercial Bank, and the Real Estate Bank. The Commercial Bank of Syria—the country’s largest state-owned bank—has long served as the primary conduit for public-sector finances. Its capital once surpassed that of all Syria’s private banks combined, due to the centralization of state deposits and transactions. It also played a key role in development projects, including a 2017 loan of SYP 20 billion (~USD 40 million at the time) to fund infrastructure at Marota City, a luxury real estate project in Damascus. By maintaining sanctions on these institutions, the EU keeps much of Syria’s banking system effectively under embargo, even as it loosens sector-wide restrictions.
Telecommunications is also caught in the net. Syriatel, the country’s largest mobile operator, remains under EU sanctions. Formerly controlled by Rami Makhlouf—Assad’s cousin—before being seized by the regime in 2020, Syriatel was a key source of foreign currency. While MTN Syria and Wafa Telecom remain unsanctioned, the continued listing of Syriatel deters external engagement across the sector and discourages investment in rebuilding critical infrastructure.
The pattern extends to electronics and media. The EU has sanctioned Syronics—Syria’s largest manufacturer of televisions and consumer electronics—as well as the General Organization of Radio and TV and the Syrian Company for Information Technology. All operate under the Ministry of Information and once formed the backbone of the state’s propaganda apparatus. While these sanctions were originally intended to curb regime disinformation, they now hinder reform efforts and complicate the rehabilitation of Syria’s media environment.
Overcompliance occurs when market participants apply sanctions more broadly than legally required—avoiding otherwise permissible transactions due to indirect links to sanctioned actors or the difficulty of assessing ownership and control structures. This behavior contributes to broader chilling effects, where legal uncertainty and perceived risk inhibit otherwise lawful economic activity.
From a sanctions design standpoint, targeting specific persons and entities offers valuable flexibility: policymakers can credibly threaten escalation or offer partial relief to influence behavior. For market actors, however, this structure creates persistent uncertainty. Companies recognize that what is legal today may be prohibited tomorrow, exposing them to compliance costs, enforcement actions, and reputational risk. In Syria’s case, many responded by preemptively exiting Syrian markets, compounding the chilling effect.
This behavior, often referred to as “de-risking,” involves firms severing ties with clients, sectors, or regions that present regulatory risks. Originally coined in the anti-money laundering and counter-terrorism financing (AML/CTF) context, de-risking now encompasses a broader range of practices: banks refusing to finance lawful deals, insurers denying coverage, and companies abandoning entire markets.
Thus, even when transactions remained technically legal, many European firms feared that engaging in Syrian markets could inadvertently involve sanctioned actors through indirect ownership or control links or result in violations of complex compliance requirements. To avoid these risks, companies often withdrew from Syrian dealings altogether. This practice creates patterns of overcompliance that often ultimately nullify the intended benefits of sectoral sanctions relief.
Some argue that overcompliance enhances the sanctions’ impact and serves as proof of effectiveness. In reality, however, this dynamic risks turning a precision policy tool into a blunt instrument and undermines the EU’s capacity to adjust sanctions in response to diplomatic developments. When companies overreact or disengage entirely, the EU loses leverage in both the “application” and “reward” phases of its sanctions bargaining strategy. Target states may doubt that easing measures will be meaningful or sustainable, and EU policymakers may find themselves unable to deliver on promised relief—further reducing the incentive for cooperation.
The EU’s 50% ownership rule exemplifies how targeted sanctions can obstruct the intended outcomes, or “peace dividends,” expected once relief begins. Under this rule, any entity owned 50% or more—directly or indirectly—by a sanctioned person or company is itself treated as sanctioned.
Consequently, market participants may sever ties with entities not officially designated solely due to indirect connections to sanctioned actors. For example, an EU bank may terminate all dealings with a Syrian bank after a shareholder or senior executive is designated, despite the bank itself remaining undesignated and transactions with it legally permissible.
The EU’s “control” standard, which requires assessing influence beyond direct ownership, adds another layer of uncertainty. In Syria, where corporate transparency is limited and many sectors are dominated by politically connected actors, firms often struggle to assess who truly holds control. Faced with vague thresholds and opaque structures, many err on the side of caution. They sever ties based on limited or inconclusive information, fearing compliance breaches more than missed business opportunities—further intensifying the chilling effect.
A series of additional challenges related to overcompliance persist, particularly concerning dual-use goods restrictions. EU exports of goods listed in Annexes I a, V, VIII, IX, and X of Regulation 36/2012 remain prohibited, including dual-use items (Annex V) and certain machinery and technology with military or repression applications (Annex I).
Annex IX of Regulation 36/2012 specifically restricts the export of chemical manufacturing equipment, including corrosion-resistant reactors, agitators, valves, heat exchangers, and storage tanks above specified thresholds (e.g., volume and material composition). While the technical scope of these measures is limited, they apply to equipment commonly used in industrial sectors such as pharmaceuticals, fertilizers, and water treatment. In a context like Syria’s—marked by extensive infrastructure degradation and limited domestic production capacity—these narrowly targeted controls, combined with widespread overcompliance by foreign suppliers, may still contribute to delays and constraints in reviving key productive sectors as sanctions easing unfolds.
As targeted sanctions increasingly blur into sectoral effects in Syria, and patterns of overcompliance persist despite recent sectoral easing, the EU must carefully assess how its sanctions framework can better support the goals of reconstruction and early recovery. Five key criteria should guide decisions on lifting, adjusting, or maintaining targeted sanctions.
Do targeted sanctions still obstruct activities the EU has already exempted or permitted?
The EU has significantly eased its sanctions on Syria following the fall of the Assad regime and as part of its efforts to support an inclusive political transition in Syria, including its swift economic recovery, reconstruction, and stabilization. The EU says it aims to facilitate engagement with Syria, its people, and businesses, in key areas of energy and transport, as well as to facilitate financial and banking transactions associated with such sectors and those needed for humanitarian and reconstruction purposes. If certain targeted sanctions continue to block transactions now explicitly authorized under sectoral suspensions, they create regulatory contradictions and undermine the EU’s policy coherence.
Assessment: When activities now explicitly permitted by the EU—for instance, in the banking and/or oil sectors—still require specific exemptions or legal workarounds due to overlapping targeted sanctions, those targeted listings should be reviewed for possible lifting.
Do targeted sanctions block critical recovery sectors or paralyze necessary economic functions?
In March 2025, concerned about Syria’s stability, Members of the European Parliament expressed their readiness to “seize this historic opportunity to support a Syrian-led political transition in order to unite and rebuild the country.” As part of broader efforts to assist Syria’s path to recovery, the European Council suspended several restrictive measures against the former Assad regime in February 2025. Kaja Kallas, the EU’s High Representative for Foreign and Security Policy, said that the EU’s priority is to ensure security in the region.
Such security and stability, however, are unlikely to materialize without a significant acceleration of economic recovery. The challenge is that even in the absence of formal sectoral bans, targeted measures against monopolistic or state-linked entities—such as public utilities, banks, or infrastructure operators—may still cripple entire sectors and/or thwart trade and cooperation between EU counterparts and actors within these industries. Maintaining these targeted measures risks neutralizing the intended benefits of lifting broader sectoral restrictions.
Assessment: The EU should prioritize delisting entities where doing so would unlock significant recovery gains, while preserving pressure on persons responsible for repression or corruption. In cases where a person/entity is both systematically important and implicated in repression and/or corruption, the decision to retain or remove them from the sanctions list should be based on the assessment that weighs the five criteria outlined in this brief.
Will lifting EU sanctions produce real effects, or will other jurisdictions’ sanctions still block re-engagement?
Even if the EU lifts certain targeted sanctions, European businesses may remain unwilling to re-engage with Syrian entities if key partners such as the US or the UK continue to enforce their own sanctions regimes. US secondary sanctions—especially under the Caesar Act—expose non-US actors to penalties for dealing with sanctioned Syrian persons or entities.
As a result, the private sector may continue to overcomply, avoiding Syrian transactions entirely, even when EU sanctions are eased or lifted. Similarly, sectors tied to major sanctioned actors—such as banking, energy, or transportation—may remain effectively crippled because firms fear entanglement with US-restricted entities. Thus, overlapping external sanctions can entrench the same sectoral paralysis and overcompliance patterns that the EU seeks to address by lifting its own measures.
Assessment: When considering adjustments to its targeted sanctions, the EU should carefully map overlaps with allied regimes and, where possible, coordinate sequencing with US and UK authorities. However, coordination should not become a precondition. If key allies pursue divergent policy objectives or if coordination risks diluting the EU’s policy impact, the EU should be prepared to move unilaterally. Otherwise, coordination risks yielding the lowest common denominator.
Could lifting sanctions empower actors who threaten European security or regional stability?
Some sanctioned persons or entities remain implicated in arms smuggling, organized crime, or terrorism financing. Delisting without safeguards could enable renewed malign activities.
Assessment: Due diligence and intelligence sharing are critical. Persons and entities posing residual security risks should remain sanctioned until credible changes in behavior or structure are demonstrated.
Would lifting sanctions release significant frozen assets, and does doing so align with the EU’s overall stance?
Frozen assets represent a key form of leverage, offering potential resources for future reconstruction, victim compensation, or transitional justice. Their appropriation, however, is a highly contentious legal and political issue. The ongoing, inconclusive debates over how to handle the frozen assets of the Russian Central Bank underscore the legal ambiguity and risks involved in any attempt to repurpose such funds. Equally, prematurely unfreezing such assets risks rewarding former regime cronies or weakening accountability efforts.
Assessment: Delisting decisions should be informed by a strategic review of the value, origin, and potential use of these assets. Any consideration of unfreezing must be accompanied by a thorough legal assessment, especially where appropriation or redirection is envisioned.
The EU’s ideal policy stance should be the full lifting of Syria-related sanctions to support reconstruction, restore economic ties, and reduce humanitarian suffering. This would allow for a clean break from punitive frameworks that have long inhibited private sector engagement and state recovery. However, if political consensus for full lifting cannot be achieved, a second-best option is to mitigate the impact of remaining targeted sanctions. This includes minimizing overcompliance, issuing clear guidance to the private sector, and ensuring that sanctions are tailored and time-bound. All recommendations and delisting considerations below operate within this hierarchy: complete lifting is the preferred course; refinement of targeted measures is a fallback.
Will lifting some targeted sanctions meaningfully reduce overcompliance and encourage businesses to return, or is additional guidance needed?
Delisting certain high-profile entities—such as major state banks, airlines, or port operators—would send a strong signal that some normal commerce can resume. However, the EU should anticipate that banks and companies may still hesitate, fearing that sanctions could “snap back,” that compliance frameworks in Syria remain inadequate, or that US measures still apply. Accordingly, any lifting decision should be accompanied by clear communication and legal assurances. For example, EU member states could issue authoritative guidance or comfort letters indicating that engaging in specified transactions with previously sanctioned entities is lawful and encouraged under EU policy (assuming it is), or that the relevant humanitarian exemptions or derogations apply.
The EU could also consider broadening the scope of existing exemptions or introducing new derogations into the legal text. This would give national competent authorities (EU member states) a clearer and more flexible legal basis to authorize specific transactions. However, a one-time comprehensive delisting of all entities essential for rebuilding infrastructure—such as oil companies, ports, and banks—is likely to be more effective than incremental changes that financial institutions may interpret as ambiguous.
Measurable criteria for success would be useful—for example, tracking whether international wire transfers to Syria increase or whether more projects secure financing. If overcompliance remains high despite EU policy shifts, the EU may need to adopt complementary measures, such as establishing an EU-backed financing vehicle for Syrian recovery that is insulated from sanctions exposure. This would mirror the approach taken with Iran, where the state-owned company Instrument in Support of Trade Exchanges (INSTEX) was created following the Trump administration’s withdrawal from the Iran nuclear deal in May 2018. The framework should focus not only on legal reforms but also on practical outcomes—namely, a measurable reduction in overcompliance—3 supported by flanking policies to ensure the private sector is both informed and reassured.
If the EU decides to lift certain targeted sanctions, can it effectively monitor the concerned actors’ behavior post-delisting and re-impose sanctions swiftly if needed?
A credible snapback threat can mitigate the risk of bad faith. However, as noted in the February 2025 adjustment, the EU did not include an automatic snapback clause—any re-listing would require a new unanimous decision. Once sanctions are lifted, reapplying them thus becomes politically difficult, as it requires agreement from all 27 member states.
The EU must be confident that delisted actors will not immediately resume malign activities—or that, if they do, sufficient evidence can be collected to justify re-listing. This underscores the need for robust intelligence-sharing and monitoring mechanisms. For example, if a Syrian company previously involved in arms smuggling is delisted to support the new government, there should be ongoing oversight, possibly in coordination with the UN or Interpol.
The EU may consider setting up a formal review process: any sanctions suspended or lifted in 2025 would be subject to reassessment by mid-2026, based on specific benchmarks (e.g., no involvement in illicit activity, no ties to proscribed groups). Failure to meet these benchmarks could trigger re-listing by the Council.
Monitoring capacity should not rest solely with the EU; it can be shared with Syrian authorities and international partners. There is also a reverse risk of overcompliance: if companies suspect that delistings are temporary, they may continue to avoid engagement. To counter this, the EU could signal that delistings are permanent unless significant violations occur, thus offering greater certainty to the private sector4.
For any targeted sanctions that remain in place, the EU should clearly communicate the conditions for their future removal—e.g., that a person will remain listed until they are tried for war crimes or a truth and reconciliation process concludes. Transparent criteria and monitoring protocols help ensure that sanctions remain conduct-based rather than status-based, reinforcing their role as a tool to incentivize behavioral change and support long-term stability.
If the EU decides to maintain the Syria sanctions regime in its 2025 annual review, it should follow the approach outlined above—reviewing all “individual” listings and determining on a case-by-case basis whether to retain or delist them, based on the criteria presented above. However, the recommended course of action is for the EU to allow the Syria-specific sanctions regime to expire, while preserving pressure on “individuals” responsible for human rights abuses, war crimes, or terrorism.
To ensure continued accountability without obstructing economic recovery, the EU should consider transferring such individuals to the Global Human Rights Sanctions Regime (Council Decision 2020/1999), which offers a horizontal legal framework for targeting perpetrators of serious abuses irrespective of geography. This shift is crucial, as the mere existence of a country-specific Syria sanctions regime contributes to de-risking and a broader chilling effect on lawful economic activity.
This approach addresses contradictions in which sanctions hinder reconstruction efforts, while supporting both the Syrian population and any legitimate governing authorities. At the same time, it demands careful management of public perception—particularly when easing restrictions on entities or individuals linked to the Assad regime.
Under the Global Human Rights Sanctions Regime, the EU can continue to sanction persons and entities—state or non-state—implicated in grave human rights violations. That regime, in force until December 2026, already includes one Syrian entity (the Syrian Republican Guard) and two persons (the former Minister of Defence and the Chief of Staff of the Syrian Army). Expanding its use enables the EU to uphold justice, avoid legal disproportion, and support Syria’s recovery without compromising on core human rights principles.
References
1 Together with the Council of the EU.
2 The EU uses a different terminology for restrictive measures. Instead of distinguishing between “targeted” and “sectoral” sanctions, it distinguishes between “individual” and “sectoral” sanctions. The EU may use sectoral sanctions in a “targeted” way, for instance, sanctioning trade of a specific chemical, as opposed to trade with a specific entity. However, in this brief, the term “targeted” refers to sanctions that target an entity/individual in principle, as opposed to sanctions that target a sector in principle.
3 Or compliance with other sanctions regimes in non-EU jurisdictions.
4 In the EU, delistings are legally permanent: entities have been deleted from the relevant Annex.