Embargoes and sanctions on Syria
This guide contains information about embargoes and sanctions on Syria, and provides information for exporters. You can find more general information here on sanctions, embargoes and restrictions, and a list of all the countries where there are current restrictions.
Almost all governments control the export of goods for different reasons, depending on the nature and destinations of the proposed exports. The export of strategic goods and technologies are controlled for various reasons including:
- concerns about a country’s internal repression of its citizens, regional instability and other human rights violations
- concerns about the development of weapons of mass destruction
- foreign policy and international treaty commitments, such as the imposition of European Union (EU) or United Nations (UN) trade sanctions or arms embargoes
- concerns for the national and collective security of the UK and its allies
Trade restrictions (which include an arms embargo) are in force on Syria.
These are EU imposed embargoes which are directly applicable in UK law.
The EU originally imposed sanctions which came into force on 10 May 2011. The current trade sanction measures in force are set out in Council Decision 2012/122/CFSP which was adopted and came into force on 27 February 2012. On the same day, the EU also issued an implementing measure, Council Regulation (EU) No 168/2012, which amends Council Regulation (EU) No 36/2012.
The EU has also imposed a further implementing measure - Council Regulation (EU) No 509/2012 - which came into force on 17 June 2012. This measure, which also amends Council Regulation EU (No 36/2012) imposes a prohibition on the sale, supply, transfer or export of listed luxury goods and certain dual-use items and chemicals.
In addition the EU have imposed a travel ban and an asset freeze on specified Syrian officials.
This guide outlines relevant information about the trade restrictions and arms embargo on Syria only. It explains the extent of the trade restrictions and outlines the UK and international laws that enforce it. You can also find out how to apply for an export licence to Syria and the basis for assessment of each licence application.
For information on financial sanctions, please refer to the HM Treasury website. For restrictions on imports from Syria, please refer to Notices issued by the Import Licensing Branch (ILB) part of the Department for Businss, Innovation and Skills (BIS).
Latest updates about Syria sanctions
Updates to the current trade and arms control sanctions are issued by the Export Control Organisation (ECO) via its ‘Notices to Exporters’ email update service. Subscribe to the ECO’s Notices to Exporters
The ECO has issued a number of recent Notices about the sanctions in place against Syria. These include:
- Notice to Exporters 2012/27 - issued on 18 June 2012 with details of Council Regulation (EU) No 509/2012 imposed by the EU on 15 June 2012 and in force on 17 June 2012.
- Notice to Exporters 2012/15 - issued on 16 March 2012 with details of restrictive measures imposed by the European Union in February 2012 and enforced by the UK in new legislation.
- Notice to Exporters 2012/04 - issued on 19 January 2012 with details of how to claim a contractual exemption for certain prohibited oil and gas items and electricity generating equipment.
- Notice to Exporters 2012/03 - issued on 19 January 2012 about publication of Council Regulation (EU) No 36/2012.
- Notice to Exporters 2011/30 - issued on 8 December 2011 about removal of Syria from open licensing coverage.
- Notice to Exporters 2011/29 - issued on 6 December 2011 about imposition of new restrictive measures on Syria adopted in Council Decision 2011/782/CFSP.
Separate notifications are also issued about financial and import sanctions.
Extent of restrictive measures imposed on Syria
There are extensive trade restrictions on Syria. These include an arms embargo, which is a ban on the export of ‘arms and related material’ (ie military ammunition, weapons and goods). This can be put in place by either the UN, the EU, the Organisation on Security and Co-operation in Europe, or at a UK national level.
The UK interprets an arms embargo as covering all goods and items on the UK Military List (which forms part of the UK Strategic Control Lists), unless stated otherwise. For more information see the guide on the UK Strategic Export Control Lists - the consolidated list of strategic military and dual-use items.
Additionally, some goods which are not on the UK Military List might also need an export licence. For more information, see the guide on Military end-use Control.
Other specific trade sanction measures adopted by the EU include:
- a prohibition on the sale, supply, transfer or export of arms and related material of all types
- a prohibition on the sale, supply, transfer or export of a list of equipment that could be used for internal repression
- a prohibition on the trade of gold, precious metals and diamonds
- a prohibition on the provision of technical or financial assistance or of brokering services related to any of the above
- an asset freeze against, and prohibitions on making funds or economic resources available (including the supply of goods) to a specified list of people held responsible for the violent repression against civilians
- a ban on cargo flights operated by Syrian carriers
- a travel ban against specific listed individuals
There are limited exemptions in place, including the transport of supplies to the United Nations Disengagement Observer Force (UNDOF) and for supply of non-lethal equipment for humanitarian or protective use.
Other measures include:
- a prohibition on the sale, supply, transfer or export of equipment or software intended for use by the Syrian regime in monitoring or interception of internet and telephone communications. Provision of technical or installation assistance in support of such items will also be prohibited. There is an exemption for pre-existing contracts
- a prohibition on the supply or transfer of specified equipment or technology to be used in certain oil and gas natural sectors in Syria or to Syrian-owned enterprises outside Syria. There is no exemption for pre-existing contracts
- a prohibition on participation in the construction of new power plants for the production of electricity in Syria, including through the provision of finance or financial assistance for such projects or the acquisition of shares in, or formation of joint ventures with, enterprises in Syria engaged in such projects
- a prohibition on the sale, supply, transfer or export of listed luxury goods
Additionally, the EU has also:
- imposed a prior authorisation (export licensing) requirement for the sale, supply, transfer or export of a further list of dual-use items which might be used for internal repression.
There are also additional restrictive measures placed on Syrian banks and insurance. These include:
- a prohibition on Syrian banks from opening new branches, subsidiaries or representative offices in EU member states and from establishing joint ventures or acquiring an interest in banks in the EU. Likewise, EU financial institutions are prohibited from doing the same activities in Syria
- member states are obliged not to provide loans or other forms of financial support to the Syrian government, together with restrictions on the supply of banknotes and coinage to the Central Bank of Syria
- a prohibition on the provision of re/insurance to the Syrian government or entities or controlled by it
If you intend to export to Syria, you should keep yourself well informed of the current situation through the media and other information channels. For further details of the financial restrictions in place on Syria you should access the current UK financial sanctions explained on the HM Treasury website. For details of import sanctions, read the import notifications issued by the Import Licensing Branch, part of BIS.
Updates to the current sanctions and embargoes situation are also issued by the ECO. Read current Notices to Exporters.
Restrictions on Syria’s oil and gas and electricity generating industries
If you are intending to export any items listed in either Annex VI or VII of Council Regulation EU (No) 36/2012 or to provide brokering services, technical or financial assistance related to those items, you are advised to read this information carefully.
As of 19 January 2012, a range of restrictive measure apply in the EU on exports to Syria’s oil and gas and electricity generating industries. The measures target both the industries within Syria and also Syrian enterprises engaged in those activities outside Syria. The measures could apply to your business if you trade with Syria, or intend to trade in goods or technology relating to:
- exploration of crude oil and natural gas
- production of crude oil and natural gas
- liquefaction of natural gas
- equipment or technology to be used in the construction or installation in Syria of new power plants for electricity production
In particular Council Regulation (EU) No 36/2012 (as amended by Council Regulation (EU) No 168/2012) specifically states the restrictions on oil and gas equipment in Articles 8 and 9, as follows:
- prohibited to sell, supply, transfer or export the key equipment or technology listed in Annex VI, directly or indirectly, to any Syrian person, entity or body, for use in Syria
- prohibited to provide, directly or indirectly, financing or financial assistance, technical assistance or brokering services related to equipment and technology listed in Annex VI, or related to the provision, manufacture, maintenance and use of goods listed in Annex VI, to any Syrian person, entity or body, or for use in Syria
- prohibited to participate, knowingly and intentionally, in any activity the object or effect of which is to circumvent the specified prohibitions
The prohibitions relating to restrictions on infrastructure projects are specified in Article 12 of the Regulation. This specifically states that it is:
- prohibited to sell, supply, transfer or export equipment or technology to be used in the construction or installation in Syria of new power plants for electricity production, as listed in Annex VII
- prohibited to provide, directly or indirectly, financing or technical assistance in relation to any infrastructure project referred to above
To gain a fuller undertanding, you are advised to download the full text of Regulation 36/2012 from the Europa website (PDF, 1.24MB).
If you are impacted by these restrictions, your first action is to refer to the items detailed in either Annex VI or Annex VII of this Regulation before you directly or indirectly sell, supply, transfer or export any listed item to any Syrian person, entity or body or for use in Syria.
In most cases, you should be able to determine this by ‘self-rating’ your items. However, if you have tried this and cannot do so, you can seek advice by submitting a Control List Classification Advice service request via SPIRE. For more details see the guide strategic exports: when to request an export licence.
There is an exemption for Annex VI and Annex VII listed goods for pre-existing contracts. The prohibitions do not apply if you have:
- a contract, subcontract or agreement which obliges you to supply the equipment or to provide technical or financial assistance or brokering services related to the equipment
- that contract was concluded before 19 January 2012
- you have notified the relevant competent authority of the transaction at least 21 calendar days in advance. In the UK this authority is the Export Control Organisation (ECO).
For further detailed information download Notice to Exporters 2012/04 about the contractual exemption concerning prohibited equipment supplied to Syria.
The completed form to claim the exemption should be emailed to email@example.com.
If the items you intend to export are not listed on either Annex VI or Annex VII, there is no prohibition on their export under the provisions. However, you will need to check that your items are not controlled or prohibited under any other provision. You should also check that the entity you are supplying is not subject to asset freeze provisions.
Applying for an export licence to Syria
Exporters can apply for an export licence for their goods. All applications will be considered by the government on a case-by-case basis in relation to the terms of the embargo and in line with the provisions of the Consolidated EU and National Arms Export Licensing Criteria. Read the guide on assessment of export licence applications: criteria and policy.
However, many of the restrictions against Syria are prohibitions. That means that there is a complete ban on supply or trade with Syria in the listed items or activity. Licences will not normally be issued where there is a prohibition in place. While there are some limited exemptions to the prohibitions, the ECO would expect to issue an export licence only in exceptional circumstances in line with the relevant exemption and after careful assessment on a case-by-case basis against the Criteria.
There are exemptions for export for humanitarian use or for use of UN personnel.
Further licensing guidance
For details on different export licences available see the guide on licences: export, trade control and transhipment.
When applying for a licence, you should be aware of the current licence processing times by destination. You can view details of licensing statistics on the ECO Reports and Statistics website.
In applying and using any licence, exporters should be aware of their responsibilities. For more information, see the guide on compliance and enforcement of export controls.
If you are unsure if your goods are controlled, you should read the guide on strategic exports: when to request an export licence.
Syria arms embargo key legislation
The arms embargo on Syria has been imposed by EU laws, and implemented in the UK by statutory instruments.
UN Security Council resolutions
There are currently no UN Security Council resolutions on Syria.
In response to the violent repression by Syrian government forces, the EU orignally imposed sanctions on Syria which came into force with immediate effect on 10 May 2011. The sanctions were originally detailed in Council Decision 2011/273/CFSP (published in the Official Journal of the European Union L121, 10.4.2011, p11) and Council Regulation (EU) No 442/2011 (published in the Official Journal of the European Union, L121, 10.4.2011, p1), now repealed.
These sanctions were then consolidated and updated by new restrictive measures announced in Council Decision 2011/782/CFSP (published in the Official Journal of the European Union L319, 2.12.2011, p56). This Decision came into force on 1 December 2011 and implemented by Council Regulation (EU) No 36/2012.
On 27 February 2012, the EU imposed new measures on Syria which were adopted in Council Decision 2012/122/CFSP (published in OJ L54, 28.2.2012, p14). Council Regulation (EU) No 168/2012 of 27 February 2012 (published in OJ L54, 28.2.2012, p1) implements the measures outlined in this Decision and also amends Regulation (EU) No 36/2012.
The EU have also adopted Council Decision 2012/123/CFSP of 27 February 2012 which concerns the partial suspension of the application of the Co-operation Agreement between the EU and the Syrian Arab Republic.
On 15 June 2012, the EU imposed Council Regulation (EU) No 509/2012. This new regulation came into force on 17 June 2012 and is published in OJ L156, 16.6.2012, p10. The regulation further amends Regulation (EU) No 36/2012.
The relevant UK laws that apply to the arms embargo on Syria are the:
- Export Control Order 2008 (SI 2008/3231), under Schedule 4, Part 2 - ‘Embargoed and Subject to Transit Control for Military Goods’.
- Export Control (Syria Sanctions) and (Miscellaneous Amendments) Order 2012 (SI 2012/810)
For more information, see the guide to the Export Control Order 2008. You can download copies of all UK legislative orders from the legislation.gov.uk website.
Other restrictions on Syria
Syria is also subject to other sanctions including assets freeze. You can view a current list of asset freeze targets designated by the United Nations (UN), European Union and United Kingdom, under legislation relating to Syria.
UK Trade & Investment Enquiry Line
020 7215 8000
BIS ECO Helpline
020 7215 4594 or Email: firstname.lastname@example.org