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US Likely to Keep Sanctioning Syria's 'Bad Actors' for Years, Ex-Official Says

While the U.S. government is going to “great lengths” to ease broad-based sanctions on Syria to allow normal business ties with the war-torn country to resume, sanctions on specific individuals and entities in Syria will probably remain in place for years to come to ensure bad actors can't access their frozen assets, according to a former Treasury Department official.

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Such a ”list-based” sanctions program could be aimed at members of the former Bashar Assad regime, human rights violators, drug traffickers and affiliates of Russia, Iran or Iraq's former Saddam Hussein regime, said Collmann Griffin, counsel at Miller & Chevalier, who worked on Syria issues as a sanctions policy adviser at the Office of Foreign Assets Control. OFAC’s sanctions tracker website currently lists about 300 individuals and entities in Syria.

The list-based program would resemble what the U.S. put in place for Iraq after Saddam's ouster in 2003. “There is going to be a sort of long tail of a Syria sanctions program, I predict, similar to what we saw in Iraq after the fall of Saddam Hussein,” Griffin told Export Compliance Daily this week. “The primary policy goal there will be to keep … the really bad guys on the list and to keep their assets frozen for potential repatriation to Syria in the future.”

The continuation of such sanctions underscores the need for those seeking to do business with Syria to perform due diligence, such as checking OFAC’s sanctions tracker and ensuring a non-sanctioned entity or property they want to work with is not owned by a sanctioned person, Griffin said. Foreign firms have expressed interest in investing in Syria’s energy sector and reconstruction efforts, as well as supplying “all sorts of products” that have been off limits to the country, he added.

Although the House Financial Services Committee in July approved a bill that would update the conditions for lifting sanctions in the Caesar Syria Civilian Protection Act of 2019 (see 2507240016), Griffin does not see the legislation as being at odds with the administration's position.

“I don’t think that there’s going to be a lot of daylight between the administration and Congress on this,” such as when it comes to the bill’s provisions aimed at protecting religious minorities, he said. “If we were to see significant targeting or extrajudicial detention of religious minorities in Syria, that's going to put political pressure on the administration to impose sanctions.”

An executive order that President Donald Trump signed June 30 removed certain financial sanctions against Syria and authorized the "relaxation" of export controls against the country (see 2506300055). The order, which aims to promote peace and stability in Syria, has received bipartisan support in Congress (see 2507010002).

Despite the administration's actions, the U.S. government will retain plenty of sanctions tools to counter bad actors, including the Global Magnitsky Human Rights Accountability Act, Griffin noted.