Guidance

Supporting a secure and prosperous future for Syria: guidance for businesses and NGOs

Published 2 December 2025

© Crown copyright 2025

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This publication is available at https://www.gov.uk/government/publications/supporting-syrias-future-guidance-for-businesses-and-aid-organisations/supporting-a-secure-and-prosperous-future-for-syria-guidance-for-businesses-and-ngos

1. Introduction

  1. In recent months, UK businesses have expressed interest in exploring doing business in Syria. This interest has been accompanied by calls for greater clarity from the UK Government regarding the legal and policy frameworks governing such investments.

  2. While there is no one size fits all approach, this information note has been prepared in response to these concerns, aiming to provide UK businesses, banks and the aid sector with a clear understanding of the relevant regulations and guidance associated with investing in Syria. It seeks to inform risk-based decision-making while promoting compliance with the UK’s international obligations, government policy, and sanctions regulations. This information note should be read in conjunction with our statutory and non-statutory guidance publications which are of relevance to your business.

  3. The UK Government is supportive of UK businesses investing, trading, and operating in Syria, where that activity is compliant with UK legislation, and where the end destination is Syria. It is the responsibility of UK businesses to fully determine the extent of their specific risk exposure, and to develop an appropriate set of safeguards and controls tailored to their circumstances. Potential risks include malign actors, including state actors, exploiting the jurisdiction of Syria for their own gain. Many states and entities subject to UK sanctions, export controls, and other prohibitions rely on deceptive tactics, such as the use of indirect shipping routes, deliberate falsification of the end-uses of traded goods, and professional networks, to evade established export controls and sanctions enforcement.

  4. Following the fall of the Assad regime in December 2024, the UK Government lifted some of its Syria sanctions in April 2025.

    In November 2025, following the adoption of UN Security Council Resolution 2799, the UK delisted the Syrian President, Ahmed al-Shara’a, and the Interior Minister, Anas Khattab, from its ISIL/Al-Qaida sanctions list.

    In October 2025, the UK decided to remove Hay’at Tahrir Al-Sham (HTS) from its list of proscribed terrorist organisations.

  5. Syria offers a potentially high return market in which to do business despite a challenging and high-risk context. The new Syrian government is working to deliver stability to Syria, including through political transition and economic recovery. For now, Syria remains a lower middle-income country according to the World Bank, but there are commercial opportunities and likely a pipeline of new commercial opportunities to come. For more information about trading with Syria, see Doing business in Syria: Syria trade and export guide.

2. The UK’s Syria sanctions regime

  1. The prohibitions are set out in the Syria (Sanctions) (EU Exit) Regulations 2019 and the UK Sanctions List lists the individuals and entities designated under this regime.

  2. On 24 April 2025, the UK amended the Syria (Sanctions) (EU Exit) Regulations 2019, removing various sanctions measures to help the people of Syria rebuild their country and economy. These amendments lifted certain sanctions in relation to trade, finance, transport (aviation) and energy production while maintaining sanctions that continue to hold Assad and his associates to account.

  3. Separately, the UK has also lifted financial sanctions (asset freezes) previously imposed on organisations which were controlled by the Assad regime, including the Central Bank of Syria, the Syrian Ministry of Defence and Interior, energy companies and media companies. These changes are intended to help facilitate essential investment into Syria and support the Syrian people to rebuild their country and economy. The Government of Syria, including its ministries, is not designated under any of the UK’s sanctions regimes.

  4. While a significant number of sanctions have now been removed under the UK’s Syria sanctions regime, a number remain in place. The remaining prohibitions include, but are not limited to:

  • asset freezes on designated individuals and entities
  • trade sanctions on the export, supply or transfer, and related services, of:
    • chemical and biological weapons-related goods and technology
    • internal repression goods and technology, and
    • interception and monitoring goods and technology
  • trade sanctions on the export, making available to, supply from a third country to, and import or acquisition from, the ‘Governing Authority of Syria’ – this means the transitional Syrian authorities and any successor authorities, and the Central Bank of Syria, or any business or organisation controlled by them – of:
    • gold, precious metals or diamonds, or the provision of related technical assistance, financial or brokering services, and
    • interception and monitoring services
  • trade sanctions on the export, making available or supply from a third country to Syria or to a person connected with Syria of:
    • luxury goods
  • trade sanctions on the import or acquisition from Syria (including from Syria to a third country, and moving from a third country if originally consigned from Syria) of:
    • military, security and para-military goods, and arms, ammunition and related material

      Note that the export of and trade in military goods and military technology are also controlled under the Export Control Order 2008 and so you may also need a licence.

5. It is important to note that these are not blanket prohibitions. There are certain defined circumstances where activities that would otherwise be prohibited are allowed, using:

  • exceptions: an exception, listed in the regulations, gives an automatic exemption to a given activity
  • licences: a licence authorises certain activities or types of transaction that would otherwise be prohibited by sanctions legislation

6. In addition to issuing licences relating to a specific person, the UK government may also issue general licences which authorise otherwise prohibited activity by a particular category of persons (who fall within the licence criteria). General licences can be used without making an application to the relevant government department. 

If the good or service is also subject to export controls, you will need to apply for a separate export control licence.

Part 7 of The Syria (Sanctions) (EU Exit) Regulations 2019 sets out the exceptions and licences which apply to this regime. For more information on the exceptions and licences applicable to the Syria regime, see section 3 of the statutory guidance: Syria sanctions: guidance.

For more information on how to apply for a licence, please see the guidance on:

7. Sanctions regulations impose reporting obligations on ‘relevant firms’ – these types are listed under Part 8 of the Regulations and in:

8. Anyone can report a suspected breach of sanctions. This online service helps you to report a suspected breach of sanctions to the correct government body.

3. The United Nations ISIL / Al-Qaida sanctions regime

  1. In addition to the UK’s Syria sanctions regime, UK persons who are considering investing in Syria should be aware that certain individuals and entities connected with Syria continue to be designated under the UN counter-terrorism sanctions regime established by UN Security Council Resolution 1267 (1999).

    This UN regime is given effect in UK law by the ISIL (Da’esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019.

    In November 2025, following the adoption of UN Security Council Resolution 2799, the UK delisted the Syrian President, Ahmed al-Shara’a and the Interior Minister, Anas Khattab, from its ISIL/Al-Qaida sanctions list.

  2. While HTS remains a designated entity under these sanctions, the Government of Syria, including its ministries, is not itself designated under any of the UK’s sanctions regimes. Interactions with the Syrian Government will therefore not necessarily engage UK sanctions. This is because HTS and the Government of Syria (which is not, and has never been, designated by the UN) are separate entities. The UN asset freeze only covers the direct or indirect provision of funds or economic resources to designated individuals or entities. Further guidance on public officials and control of public bodies is available in the Ownership and Control: Public Officials and Control guidance.

  3. There are a number of measures that apply specifically to designated individuals and entities (designated persons) which are set out in the statutory guidance, ISIL (Da’esh) and Al-Qaida sanctions: guidance. These prohibitions on designated persons include, but are not limited to:

  • an asset freeze on their funds and other assets
  • making funds or economic resources available to them or for their benefit
  • the export, supply, delivery, making available and transfer of military goods and technology, and related services (as specified in schedule 2 to the export control order 2008)
  • provision of services that enable or facilitate armed hostilities

4. It is important to note that these are not blanket prohibitions. There are certain defined circumstances where activities that would otherwise be prohibited, are allowed, using:

5. Sanctions regulations impose reporting obligations on ‘relevant firms’ – these types are listed under Part 7 of the Regulations and in:

Anyone can report a suspected breach of sanctions. This online service helps you to report a suspected breach of sanctions to the correct government body.

4. UK counter-terrorism legislation (proscribed organisations) relevant to Syria

  1. As announced on 21 October 2025, the UK Government has decided to remove Hay’at Tahrir Al-Sham (HTS) from the list of proscribed terrorist organisations. Deproscribing HTS is part of the UK’s response to the significant developments in Syria since forces led by President Al-Sharaa toppled the Assad regime last December. HTS was originally listed as an alias of proscribed organisation Al-Qa’ida in 2017. HTS remains subject to UN sanctions which continue to have effect in UK law as set out above.

    The deproscription of HTS will mean that the proscription offences set out in the Terrorism Act 2000, including the offences of membership and inviting support for proscribed organisations, will no longer apply to HTS.

  2. Da’esh, or ISIL (also known as Islamic State in Iraq and Syria, or ISIS), is a proscribed organisation and remains a significant threat in Syria. The de-proscription of HTS aligns with the government’s counter-Da’esh mission in Syria, in turn reducing the threat to the UK.

  3. HMG is committed to ensuring that counter-terrorism legislation is applied in an effective manner that is proportionate to risk and without compromising other HMG priorities or unnecessarily impeding legitimate humanitarian activities.

    It has been the view of consecutive UK Governments that the counter-terrorism legislative framework does not prevent organisations operating in Syria and acknowledges that those working in high-risk jurisdictions face a unique and complex operating environment.

  4. The Crown Prosecution Service (CPS) has issued specific guidance to clarify how terrorist finance and other offences are assessed in relation to humanitarian, development and peacebuilding work. This guidance was developed following a recommendation by the Independent Reviewer of Terrorism Legislation.

    The CPS recognises the important work undertaken to deliver humanitarian, development and peacebuilding efforts internationally, and the guidance states that counter-terrorism legislation is not intended to hinder such work. Where it is alleged that an organisation has committed an offence, careful consideration of whether it is in the public interest to bring a prosecution will be required. Consideration of what due diligence measures were put in place to actively comply with UK law may be relevant in determining whether a prosecution is in the public interest.

  5. No individual from an International NGO or body corporate has been prosecuted by the CPS for terrorism offences relating to humanitarian, development or peacebuilding work.

5. Humanitarian provisions, exemptions, and general licences applicable to Syria

The UK Terrorism Act provisions

  1. There are some provisions in the legislative framework that address the challenges of operating in high-risk contexts. For example, there are provisions within proscription offences, including a defence under Section 12(4) of TACT 2000 for ‘genuinely benign’ meetings with a proscribed organisation, which can include meetings that facilitate the delivery of humanitarian aid. Similarly, sections 21ZA and 21ZB of TACT 2000 provide a route to seek a defence from the National Crime Agency (NCA) for a future or historical transaction that would otherwise be a terrorist financing offence.

The UN humanitarian exemption

2. In December 2022, the UN Security Council introduced a cross-cutting humanitarian exemption to the asset freeze measures across all UN sanctions regimes. This was intended to enable the unimpeded delivery of humanitarian assistance and other activities that support basic human needs and to address the unintended consequences of sanctions for humanitarian action.

3. The UN humanitarian exemption (UNSCR 2664) was incorporated into the UK’s UN and mixed sanctions regimes in February 2023 by the Sanctions (Humanitarian Exception) (Amendment) Regulations 2023. In the ISIL (Da’esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019, the humanitarian exception is set out at Regulation 27ZA. This provides that relevant activities carried out by a person which are necessary to ensure the timely delivery of humanitarian assistance, or to support other activities that support basic human needs carried out by eligible organisations (see Condition A in Regulation 27ZA), do not contravene the asset freeze prohibitions in the regulations.

4. The UK humanitarian exception is intended to implement paragraph (1) of UNSCR 2664 (2022), which states that the provision, processing or payment of funds, other financial assets, or economic resources, or the provision of goods and services necessary to ensure the timely delivery of humanitarian assistance or to support other activities that support basic human needs carried out by eligible organisations are permitted and not a violation of asset freezes. View the Explanatory Memorandum on the UK humanitarian exception.

5. The government recognises the vital role of businesses, the finance sector, and other providers of goods and services, alongside aid organisations, in supporting humanitarian aid and basic service delivery in the ongoing humanitarian rehabilitation of Syria. This will include the recovery and reconstruction activities needed to help rebuild the lives and livelihoods of the Syrian people.

See also OFSI’s Financial sanctions guidance for charities and non-governmental organisations (NGOs).

6. We have committed to bring forward legislation when parliamentary time allows to introduce a tailored humanitarian exception across all the UK’s autonomous financial sanctions, including for Syria, as outlined in the Government’s response to the independent review of the international counter terrorism sanctions, December 2023. This will build on the UK’s role in helping to secure the UN Security Council’s landmark resolution 2664.

The UK’s Syria sanctions regime – humanitarian petroleum products exception and humanitarian activity general licence

7. Under the UK’s Syria sanctions regime, a relevant person may make use of these specific provisions:

  • an exception in relation to acquiring, supplying or delivery petroleum products for humanitarian purposes (see section 3.1 of the statutory guidance)
  • the general licence in relation to humanitarian activity (see Syria_Humanitarian_GL_INT.2025.5810196.pdf)

    This exception and licence protect a relevant person against committing possible breaches in relation to making funds available to designated persons when carrying out humanitarian assistance and other activities that support basic human needs.

Humanitarian exception relating to petroleum products

8. The Syria (Sanctions) (EU Exit) Regulations 2019 contain a humanitarian exception relating to petroleum products (regulation 57). This exception (to the extent that it remains relevant – see paragraph 9 below) applies when a ‘relevant person’ makes available funds or economic resources for the purposes of either:

  • acquiring, supplying or delivering petroleum products, or
  • providing funds, economic resources or financial services in relation to those activities; and where the petroleum products are acquired, supplied or delivered exclusively for the purposes of providing a humanitarian assistance activity

    The exception to the asset freeze prohibitions also applies to persons providing financial services, funds or economic resources to a ‘relevant person’ in relation to their reliance on the exception.

    For full details of organisations that are eligible to use this exception, see regulation 57. To review the 2024 amendments to the humanitarian exception relating to petroleum products, go to the explanatory memorandum to the Syria (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2024.

9. The Syria (Sanctions) (EU Exit) Regulations 2019 were amended earlier this year (with effect from 25 April 2025) to remove the prohibitions on the purchase, acquisition and transport of petroleum products, and related services. This means that the humanitarian exception relating to petroleum products is no longer needed in relation to those prohibitions and only continues to apply in relation to the prohibitions in regulations 12 to 15 – making funds or economic resources available to, or for the benefit of, designated persons. Similarly, the Treasury notification requirement under regulation 57(5) now only applies where the exception is relied upon in relation to the prohibitions in regulations 12 to 15.

Therefore, for relevant humanitarian assistance activity which involved petroleum products prior to 25 April, we would still expect notification to be made before the end of the year under regulation 57(5) where the exception was being relied upon under the Regulations prior to their amendment. In relation to any such activity involving petroleum products on or after 25 April, notification is now only required where that activity would otherwise contravene the remaining prohibitions (ie the asset freeze) if it were not for the exception.

To comply with the notification requirement for the use of this exception, use the Notification form for humanitarian assistance exception (relating to petroleum products).  

Humanitarian activity general licence

10. On 12 February 2025, under the Syria (Sanctions) (EU Exit) Regulations 2019, OFSI issued a General Licence: Humanitarian Activity in relation to Syria. This is intended to enable the unimpeded delivery of humanitarian assistance and other activities that support basic human needs in Syria. This licence only applies to the UK’s autonomous sanctions in Syria: it does not apply in relation to relevant UN sanctions which, as set out above, have their own humanitarian exception.

11. This general licence exempts ‘relevant persons’ from the asset freeze prohibitions when they are carrying out ‘relevant activities’. Relevant persons are defined as the same list of eligible organisations set out in Regulation 57(7) of the Syria Regulations. ‘Relevant activities’ are humanitarian assistance or other activities to support basic needs and any provision of goods and services necessary to ensure the timely delivery of such assistance or to support such activities.

12. Further, ‘relevant institutions’ (which are also defined and are mainly certain types of financial institutions) may carry out any kind of activity which is necessary to allow relevant persons to carry out permitted relevant activities.

6. Further information

Sanctions guidance 

The UK Sanctions List lists the people designated under the Regulations, and details of the sanctions in respect of which they have been designated. The prohibitions in the two regimes are set out in the Syria (Sanctions) (EU Exit) Regulations 2019 and the ISIL (Da’esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019 respectively. The statutory guidance is designed to give an overview of the prohibitions and requirements in the Regulations and, where appropriate, direct you to further detailed guidance to read alongside it. The statutory guidance for these two regimes can be found here: Syria sanctions: guidance and here: ISIL (Da’esh) and Al-Qaida sanctions: guidance respectively.  

As part of our ongoing effort to improve the tools and services the UK government provides to the private sector to facilitate sanctions compliance, we’ve made it easier to navigate and find sanctions content on GOV.UK. A new sanctions hub page launched on 5 June 2025, listing all core sanctions content in a single page including a new search function for all sanctions content. We have also created a new guide Starter guide to UK sanctions on GOV.UK. This provides an entry-level guide for non-specialists that introduces key concepts and explains different types of UK sanctions. 

For timely notifications about all new and updated designations, sanctions announcements, notices to exporters and updates on sanctions guidance, sign up to to get UK sanctions email alerts.

Counter-terrorism guidance 

The prohibitions in the terrorism legislation are set out in the TACT 2000. This ‘for information note’ provides information on counter-terrorism legislation including the counter-terrorism elements of sanctions and export control that may be of relevance to those individuals and entities delivering development and humanitarian assistance in high-risk jurisdictions: For information note: operating within counter-terrorism legislation, counter-terrorism sanctions and export control. 

Roles and responsibilities across government for counter-terrorism and sanctions

The roles and responsibilities across government for counter-terrorism, sanctions, and trading with Syria are set out here: 

If you have any further queries, please contact the relevant government department. 

Other relevant regulations 

As we re-engage with Syria to support its peaceful and inclusive recovery, we encourage UK businesses to invest responsibly, ensuring compliance with all relevant legal frameworks. The UK Syria sanctions regime, the UN counter-terrorism sanctions regime (to the extent that it is relevant to Syria), and UK counter-terrorism legislation, are not the only legal provisions relevant to UK persons trading with Syria.  

Others include, but are not limited to: 

If you are unclear about any aspect of relevant legislation or guidance applicable to trading with Syria, in particular about whether action you are considering taking could contravene this, you should seek independent legal advice. 

Further guidance 

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