EO 14312Executive OrderTrump 47 · R

Executive Order 14312

Providing for the Revocation of Syria Sanctions

This executive order terminates the national emergency declared in 2004 and revokes six sanctions executive orders targeting Syria, effective July 1, 2025, while expanding a separate sanctions framework to hold the former Assad regime accountable. It directs waivers under the Syria Accountability Act, CBW Act, and Caesar Act to ease export controls and other restrictions, and mandates review of terrorism designations including for Hay'at Tahrir al-Sham and Syria's State Sponsor of Terrorism status.

Impact dates

  1. Secretary of State briefing to Congress within 30 days of any Caesar Act suspension determination

  2. CBW Act waiver effective 20 days after transmission to congressional committees

  3. Termination of national emergency and revocation of six Syria sanctions EOs takes effect

Market exposure

Policy exposure mapping — not investment advice. Illustrative public companies are incomplete and not recommendations.

Mechanisms

Ban / prohibitionLicensingSubsidy / incentive

Role pressure

  • MixedDomestic producerUS exporters of controlled technologies and goods to Syria gain new market access via waivers, but terrorism-related restrictions and remaining SDN designations create compliance uncertainty
  • MixedImporterPotential opening for Syrian-origin goods, but sanctions architecture remains complex with expanded EO 13894 targeting former regime elements
  • MixedTrading-partner exporterRegional trading partners (Turkey, Jordan, Lebanon, UAE) may benefit from normalized Syrian trade, but risk of secondary sanctions if linked to designated persons persists

Geographies

Exposure dates

  • Termination of national emergency and revocation of six Syria sanctions EOs takes effect

Illustrative public companies

Curated watchlist matches by sector/role — incomplete; not a recommendation.

MMM3MALBAlbemarleGOOGLAlphabetAAPLAppleBACBank of AmericaBASFYBASFBLKBlackRockCATCaterpillarLNGCheniere EnergyCVXChevronCOPConocoPhillipsCTVACortevaDACDanaosDOWDowDDDuPontXOMExxon MobilFCXFreeport-McMoRanGEVGE VernovaGSGoldman SachsHONHoneywellHSBCHSBCQQQInvesco QQQ TrustJPMJPMorgan ChaseLYBLyondellBasell

Confidence: medium · Policy alerts

Key directives

  • Terminate national emergency declared in EO 13338 and revoke six Syria sanctions EOs effective July 1, 2025
  • Waive Syria Accountability Act subsections (a)(1) for Commerce Control List items and (a)(2)(A)
  • Waive CBW Act sanctions sections 307(a)(1), (a)(4), (a)(5), 307(b)(2)(C), and 307(b)(2)(B); effective 20 days after congressional transmission
  • Examine and potentially suspend Caesar Act sanctions under section 7431(a); briefing to Congress within 30 days of determination
  • Expand and amend EO 13894 to target former Assad regime officials, human rights abusers, captagon traffickers, and those responsible for missing US nationals
  • Amend EO 13606 preamble to reference EO 13894 instead of EO 13338
  • Review HTS/Al-Nusrah Front FTO and SDGT designations and Ahmed al-Sharaa SDGT designation
  • Review Syria State Sponsor of Terrorism designation
  • Explore UN sanctions relief avenues
  • Submit CBW Act waiver report to Congress

Who is ordered

Timeline

Immediate

  • Termination of national emergency and revocation of EO 13338, 13399, 13460, 13572, 13573, 13582 effective July 1, 2025
  • Waiver of Syria Accountability Act restrictions on Commerce Control List items and certain financial provisions
  • CBW Act waiver effective 20 days after transmission to Congress

Near term (90d)

  • Secretary of State examination of Caesar Act criteria and potential suspension determination
  • Congressional briefing within 30 days of any Caesar Act suspension determination
  • CBW Act waiver transmission to Congress triggering 20-day countdown
  • Review of HTS/Al-Nusrah Front FTO and SDGT designations
  • Review of Syria State Sponsor of Terrorism designation
  • UN sanctions relief exploration

Long term

  • Potential reimposition of Caesar Act sanctions if criteria no longer met
  • Implementation of expanded EO 13894 sanctions framework against former regime accountability targets
  • Rules and regulations adoption by State, Treasury, Commerce
  • Syrian political transition support (constitutional process, elections)

Risks & tensions

  • Congressional pushback likely on Caesar Act suspension given bipartisan support for original legislation
  • Expanding EO 13894 while revoking older sanctions creates dual-track policy that may confuse compliance
  • Terrorism designation review for HTS/al-Sharaa carries reputational and security risks if delisted too quickly
  • CBW Act waiver 20-day delay creates brief uncertainty for exporters
  • 'Without providing relief to ISIS or other terrorist organizations' caveat may limit actual sanctions relief in practice
  • Vague 'appropriate action' and 'explore avenues' language in UN and counterterrorism sections reduces enforceability
Executive Order 14312: Providing for the Revocation of Syria Sanctions · Executive Orders