The Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025
The Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025 amend the 2019 Syria sanctions regulations.
Key changes include updating the definition of the 'Assad regime', revising the regulations' stated purposes to include promoting Syrian peace and accountability for human rights abuses, and altering designation criteria for sanctioned individuals and entities.
The amendments also significantly reduce the scope of sanctions, particularly those limiting trade, financial services, and the aviation sector, to facilitate economic recovery in Syria.
The regulations remove obsolete provisions related to previous sanctions on the Syrian regime and replace references to 'Syrian regime person' with references to a newly defined 'Governing Authority of Syria'.
Arguments For
Intended benefits: Updates sanctions regime to reflect the changed political landscape in Syria, supports Syria's economic recovery by removing some sanctions, and promotes peace, stability, and respect for human rights.
Evidence cited: The regulations cite the fall of the Assad regime and the need for changes to the sanctions regime. The impact assessment focuses on reduction of burdens on businesses.
Implementation methods: The amendments are made directly to the 2019 Regulations. Enforcement relies on existing mechanisms within the Sanctions and Anti-Money Laundering Act 2018
Legal/historical basis: The regulations are made under the powers provided by the Sanctions and Anti-Money Laundering Act 2018 and amend the Syria (Sanctions) (EU Exit) Regulations 2019, reflecting post-Brexit adjustments.
Arguments Against
Potential impacts: The removal of certain sanctions might inadvertently benefit entities that do not support peace and human rights efforts. There’s the risk of unintended economic consequences in Syria.
Implementation challenges: Ensuring effective monitoring to prevent sanctions evasion and ensuring consistent enforcement across all relevant sectors is crucial.
Alternative approaches: Instead of removing sanctions entirely, other approaches could focus on targeted sanctions against specific actors and groups known to be impeding Syria’s recovery.
Unintended effects: Removing some sanctions (as opposed to a precisely targeted approach) could create instability or potentially support undesirable economic players within Syria.
- Citation, commencement and extent (1) These Regulations may be cited as the Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025. (2) These Regulations come into force on 25th April 2025. (3) These Regulations extend to England and Wales, Scotland and Northern Ireland.
This section provides the official title of the regulations, sets their effective date as April 25th, 2025, and specifies that these regulations apply across all four nations of the UK.
- Amendments to the Syria (Sanctions) (EU Exit) Regulations 2019 The Syria (Sanctions) (EU Exit) Regulations 2019 are amended in accordance with regulations 3 to 24.
This section indicates that the following sections of the document will detail specific amendments to the 2019 Syria (Sanctions) (EU Exit) Regulations.
- Amendments to regulation 2 (interpretation) In regulation 2 (interpretation)— (a) omit the definitions of “aircraft licence” and “the Syrian regime”; and (b) after the definition of “arrangement”, insert— ““the Assad regime” means the regime in Syria from 9th May 2011 to 8th December 2024 led by Bashar Al-Assad and includes its public bodies, corporations or agencies, or any person who acted on its behalf or at its direction;”,
Regulation 2 is amended.
The definitions of 'aircraft licence' and 'Syrian regime' are removed.
A new definition of 'the Assad regime' is added, specifying its duration (9 May 2011 - 8 December 2024) and incorporating individuals acting on its behalf.
- Amendments to regulation 3 (application of prohibitions and requirements outside of the United Kingdom) In regulation 3 (application of prohibitions and requirements outside of the United Kingdom)— (a) in paragraph (2) omit “or a prohibition imposed by a condition of an aircraft licence,”; (b) omit paragraph (3)(d); and (c) in paragraph (5) omit “or a requirement imposed by a condition of an aircraft licence,”.
Regulation 3, concerning the extraterritorial application of sanctions, is altered.
References to 'aircraft licences' are removed from paragraphs (2) and (5), and paragraph (3)(d) is deleted entirely.
- Amendment to regulation 4 (purposes) For regulation 4 (purposes) substitute— “Purposes 4. The purposes of the regulations contained in this instrument that are made under section 1 of the Act are— (a) to promote the peace, stability and security of Syria; (b) to promote respect for democracy, the rule of law and good governance in Syria, including in particular promoting the successful completion of Syria’s transition to a democratic country; (c) to discourage actions, policies or activities which repress the civilian population in Syria; (d) to promote compliance with international human rights law and respect for human rights in Syria, including in particular, respect for— (i) the right to life of persons in Syria; (ii) the right of persons in Syria not to be held in slavery or required to perform forced or compulsory labour; (iii) the right of persons not to be subjected to torture or cruel, inhuman or degrading treatment or punishment in Syria; (iv) the right to liberty and security of persons in Syria, including freedom from arbitrary arrest, detention or enforced disappearance; (v) the right to a fair trial of persons charged with criminal offences in Syria; (vi) the rights of journalists, human rights defenders, civil society activists, religious leaders, politicians and all other persons in Syria to freedom of expression, peaceful assembly and association with others; (vii) the enjoyment of rights and freedoms in Syria without discrimination, including on the basis of a person’s sex, race, colour, language, religion, political or other opinion, national or social origin, association with a national minority, property, birth or other status; (e) to provide accountability for gross violations of human rights carried out by or on behalf of the Assad regime.”.
Regulation 4, outlining the purposes of the sanctions, is replaced with a revised version.
The new version adds goals such as promoting peace and stability, supporting a democratic transition, discouraging repression, and promoting human rights in Syria and holding accountable those responsible for gross human rights violations.
- **Amendments to regulation 6 (designation criteria: meaning of “involved person”) In regulation 6 (designation criteria)— (a) for paragraph (2)(a)(ii) substitute “activities carried out on behalf of the Assad regime, implementing or connected to the repressive policies of that regime;”, (b) after paragraph (2)(a)(ii) insert— (iii) supporting or benefitting from the Assad regime; (iv) the commission of, or the obstruction of an independent investigation into, a serious human rights violation or abuse in Syria; (v) the commission of a violation of international humanitarian law in Syria; (vi) undermining democracy, the rule of law and good governance in Syria; (vii) the obstruction of humanitarian assistance activity in Syria; (viii) any other action, policy or activity which threatens the peace, stability or security of Syria;, (c) in paragraph 3(a) after “Syria” insert “during the period of the Assad regime”, (d) in paragraph (3)(b) for “Syrian regime” substitute “Assad regime”, (e) in paragraph (3)(d) for “paragraph (2)(a)(i)” substitute “paragraphs 2(a)(i), (ii) or (iv) to (vii)”.
Regulation 6, defining criteria for designating individuals and entities for sanctions, is updated.
New criteria are added for those supporting or benefiting from the Assad regime, committing or obstructing investigations into human rights abuses, violating international humanitarian law, undermining governance, obstructing humanitarian aid, or otherwise threatening Syrian peace and stability.
Existing criteria are revised to align to the new definition of the Assad regime.
- Amendments to regulation 19 (sale or purchase of bonds) In regulation 19 (sale or purchase of bonds)— (a) in paragraph (1)— (i) for “Syrian bonds” substitute “Assad regime bonds”; (ii) for “Syrian regime” substitute “Assad regime”; (iii) for “after 19th January 2012” substitute “between 19th January 2012 and 8th December 2024”; (b) in paragraph (2)— (i) for “Syrian bonds” substitute “Assad regime bonds”; (ii) for “Syrian regime” substitute “Assad regime”; (iii) for “after 19th January 2012” substitute “between 19th January 2012 and 8th December 2024”; (c) in paragraph (3)— (i) for “issue Syrian bonds” substitute “sell or purchase Assad regime bonds”; (ii) for “Syrian regime” substitute “Assad regime”; (d) in paragraph (4)— (i) omit sub-paragraph (a); (ii) for sub-paragraph (b) substitute “a Syrian credit or financial institution”; (iii) in sub-paragraph (c) omit “(a) or”; (iv) in sub-paragraph (d) omit “(a),”; (e) in paragraph (7)— (i) for ““Syrian bonds”” substitute ““Assad regime bonds””; (ii) for “Syrian regime” substitute “Assad regime”; (f) after paragraph (7) insert— (8) For the purposes of this regulation, “Syrian credit or financial institution” means— (a) a credit or financial institution domiciled in Syria; or (b) a branch or subsidiary, wherever located, of a credit or financial institution domiciled in Syria.
Regulation 19, concerning bond sales and purchases, is amended.
References to 'Syrian bonds' and the 'Syrian regime' are replaced with 'Assad regime bonds' and 'Assad regime'.
The temporal scope of bond prohibitions is clarified.
Other amendments streamline provisions related to Syrian financial institutions.
- Amendment to regulation 22 (circumventing etc prohibitions) In regulation 22(1)(a) for “regulations 11 to 21” substitute “regulations 11 to 15 or 19”.
Regulation 22, on sanctions evasion, is modified to clarify that circumvention applies to regulations 11 to 15 or 19.
- Amendments to regulation 23 (interpretation of Part 3) In regulation 23 (interpretation of Part 3)— (a) in paragraph (1)— (i) in the definition of “branch” omit sub-paragraph (a); (ii) omit the definition of “UK credit or financial institution”; (b) in paragraph (2)— (i) omit sub-paragraph (b) (and the “and” which precedes it); and (ii) for “are to be read” substitute “is to be read”.
Regulation 23, providing interpretations for Part 3, is revised.
Sub-paragraph (a) from the definition of 'branch' and the definition of 'UK credit or financial institution' are removed.
Changes are made to paragraph (2) to streamline grammatical structure.
- Amendments to regulation 27 (interpretation of other expressions used in Part 5) In regulation 27 (interpretation of other expressions used in Part 5), for paragraph (6), substitute— “(6) For the purposes of Chapter 4, “the Governing Authority of Syria” means— (a) the transitional Syrian authorities formed on 8 December 2024 and any successor authorities appointed thereto; (b) the Central Bank of Syria; (c) a person acting on behalf, or at the direction, of a person mentioned in sub-paragraph (a) or (b); (d) a person who is not an individual and who is, or was, owned or controlled directly or indirectly (within the meaning of regulation 7) by a person mentioned in sub-paragraph (a) or (b).”.
Regulation 27 is amended to replace paragraph 6 with a new definition of 'the Governing Authority of Syria', including transitional authorities, the Central Bank of Syria, and those acting on their behalf or under their control.
- Amendments to regulation 38 (transport of military goods, crude oil and petroleum products) In regulation 38 (transport of military goods, crude oil and petroleum products)— (a) in the heading, omit “, crude oil and petroleum products”; (b) omit paragraph (2); (c) omit paragraph (3)(a); (d) in paragraph (4) for “Paragraphs (1) and (2) are” substitute “Paragraph (1) is”; (e) in paragraph (5) omit “or (2)” in both places it occurs; and (f) in paragraph (6) omit the definition of “non-UK country”.
Regulation 38, concerning the transport of military goods, is amended.
References to crude oil and petroleum products are removed from the heading and from relevant paragraphs.
Paragraphs (2), (3)(a), and elements within paragraphs (4), (5), and (6) are also removed.
- Amendments to regulation 42 (goods prohibitions relating to gold, precious metals or diamonds) In regulation 42 (goods prohibitions relating to gold, precious metals or diamonds)— (a) in paragraphs (1) to (3) for “a Syrian regime person”, in each place it occurs, substitute “the Governing Authority of Syria”; and (b) for paragraph (5) substitute— (5) A person who contravenes a prohibition in paragraph (3) commits an offence, but— (a) it is a defence for a person charged with an offence of contravening paragraph (3)(a) to show that the person did not know and had no reasonable cause to suspect that the supply or delivery of gold, precious metals or diamonds was to the Governing Authority of Syria; (b) it is a defence for a person charged with an offence of contravening paragraph (3)(b) to show that the person did not know and had no reasonable cause to suspect that the gold, precious metals or diamonds were being made available to the Governing Authority of Syria; (c) it is a defence for a person charged with an offence of contravening paragraph (3)(c) to show that the person did not know and had no reasonable cause to suspect that the supply or delivery of gold, precious metals or diamonds was from the Governing Authority of Syria; (d) it is a defence for a person charged with an offence of contravening paragraph (3)(d) to show that the person did not know and had no reasonable cause to suspect that the acquisition of gold, precious metals or diamonds was from the Governing Authority of Syria.
Regulation 42, on gold and precious metals prohibitions, is changed to replace 'Syrian regime person' with 'the Governing Authority of Syria' throughout.
The defence clause in paragraph (5) is rewritten to reflect the change.
- Amendments to regulation 43 (technical assistance relating to gold, precious metals or diamonds) In regulation 43 (technical assistance relating to gold, precious metals or diamonds)— (a) in paragraph (1) for “a Syrian regime person” substitute “the Governing Authority of Syria”; and (b) in paragraph (3) for “the person was a Syrian regime person” substitute “the provision of technical assistance was to the Governing Authority of Syria”.
Regulation 43, concerning technical assistance related to gold and precious metals, is updated.
All instances of 'Syrian regime person' are changed to 'the Governing Authority of Syria'.
- Amendments to regulation 44 (financial services and funds relating to gold, precious metals or diamonds) In regulation 44 (financial services and funds relating to gold, precious metals or diamonds)— (a) in paragraphs (1) to (3) for “a Syrian regime person”, in each place it occurs, substitute “the Governing Authority of Syria”; (b) omit paragraph (5); (c) in paragraph (6)— (i) for “paragraph (3)” substitute “paragraph (1), (2) or (3)”; and (ii) for “that paragraph” substitute “paragraph (1), (2) or (3) (as the case may be)”.
Regulation 44, on financial services related to gold and precious metals, is revised.
References to 'Syrian regime person' are replaced and paragraph (5) is removed.
Paragraph (6) is also amended for clarity.
- Amendments to regulation 45 (brokering services: non-UK activity relating to gold, precious metals or diamonds) In regulation 45 (brokering services: non-UK activity relating to gold, precious metals or diamonds)— (a) in paragraphs (1) and (2) for “a Syrian regime person”, in each place it occurs, substitute “the Governing Authority of Syria”; (b) omit paragraph (4); (c) in paragraph (5)— (i) for “paragraph (2)” substitute “paragraph (1) or (2)”; and (ii) for “that paragraph” substitute “paragraph (1) or (2) (as the case may be)”.
Regulation 45, about brokering services related to gold and precious metals across borders, is amended.
Occurrences of 'Syrian regime person' are replaced, paragraph (4) is removed, and paragraph (5) is adjusted.
- Amendments to regulation 48 (provision of interception and monitoring services) In regulation 48 (provision of interception and monitoring services), in paragraph (1) and (3) for “the Syrian regime”, in both places it occurs, substitute “the Governing Authority of Syria”.
Regulation 48, concerning interception and monitoring services, is updated to replace 'the Syrian regime' with 'the Governing Authority of Syria'.
- Amendments to regulation 58 (trade: exceptions from further provisions) In regulation 58 (trade: exceptions from further prohibitions)— (a) Omit paragraphs (1) and (2); (b) in paragraph (4)— (i) for “the chemical weapons programme of the Syrian regime”, substitute “chemical weapons in Syria”; (ii) in sub-paragraph (b) omit “, insofar as it relates to military goods”; and (c) in paragraph (5) omit the definitions of “aviation fuel and aviation fuel additives” and “non-Syrian aircraft”.
Regulation 58, on trade exceptions, has been modified: paragraphs (1) and (2) are deleted; paragraph (4) is modified regarding chemical weapons and military goods references.
Definitions related to aviation fuel and aircraft are also removed.
- Amendments to regulation 60 (exception for acts done for purposes of national security or prevention of serious crime)— In regulation 60 (exception for acts done for purposes of national security or prevention of serious crime)— (a) in paragraph (1) for “, 5 (Trade) or 6 (Aircraft)” substitute “or 5 (Trade)”; and (b) in paragraph (2) omit “Part 6 (Aircraft),”.
Regulation 60, dealing with exceptions for national security purposes, is adjusted.
References to Part 6 (Aircraft) are removed; the text is adjusted accordingly.
- Amendments to regulation 61 (Treasury licences) In regulation 61 (Treasury licences)— (a) in paragraph (1) omit “, regulation 16 (UK credit or financial institutions) and regulation 21 (investments in relation to crude oil and electricity production)”; and (b) omit paragraph (2)(b) (and the “and” which precedes it).
Regulation 61, concerning Treasury licenses, is updated.
References to specific regulations (16 and 21) regarding financial institutions and investments are removed from paragraph (1), and sub-paragraph (2)(b) is deleted.
- Amendment to regulation 64 (licences: general provisions) In regulation 64 (licences: general provisions), in paragraph (1), omit “aircraft licences,”.
Regulation 64, on general licensing provisions, is amended by removing reference to 'aircraft licences'.
- Amendment to regulation 77 (disclosure of information) In regulation 77 (disclosure of information), in paragraph (1)(b)(i), for “, Part 5 (Trade) or Part 6 (Aircraft)” substitute “or Part 5 (Trade)”.
Regulation 77, regarding disclosure of information, is altered.
References to Part 6 (Aircraft) are removed from paragraph (1)(b)(i).
- Amendments to regulation 79 (penalties for offences) In regulation 79 (penalties for offences)— (a) in paragraph (1) omit “, regulation 53(1), (2) and (3) (aircraft: offences); (b) in paragraph (3) omit “67 (aircraft: licensing offences),”; and (c) in paragraph (4) omit “53(4) (aircraft: disclosure of information offence),”.
Regulation 79, on penalties, is changed by removing references to aircraft-related offences in paragraphs (1), (3), and (4).
- Amendment to regulation 81 (jurisdiction to try offences) In regulation 81 (jurisdiction to try offences), in paragraph (1), omit “Part 6 (Aircraft),” and “67 (aircraft: licensing offences),”.
Regulation 81, regarding jurisdiction, is modified to remove references to 'Part 6 (Aircraft)' and specific aircraft-licensing offences.
- Omission of provisions in the Syria (Sanctions) (EU Exit) Regulations 2019 Omit— (a) regulation 16 (UK credit or financial institutions: accounts and correspondent banking relationships etc); (b) regulation 17 (opening of, or taking up of business by, a representative office, branch or subsidiary of Syrian credit or financial institution); (c) regulation 18 (acquisition or extension of ownership interest by Syrian credit or financial institution); (d) regulation 20 (insurance and reinsurance services); (e) regulation 21 (investments in relation to crude oil and electricity production); (f) in regulation 25(1) (definitions relating to goods and technology prohibited under Part 5), the definitions of “aviation fuel and aviation fuel additives”, “bank notes or coinage”, “crude oil and petroleum products”, “goods relating to crude oil and natural gas”, “goods relating to electricity production” and “technology relating to crude oil and natural gas”; (g) in regulation 28 (application of prohibitions in Chapter 2 of Part 5)— (i) paragraphs (2)(a) and (c); (ii) paragraph (3)(d); (h) in regulation 33 (prohibition relating to the associated provision of technical assistance), paragraph (4); (i) in regulation 34 (prohibitions relating to the associated provision of financial services and funds), paragraph (6); (j) in regulation 35 (prohibitions relating to the associated provision of brokering services: non-UK activity), paragraph (5); (k) in regulation 36 (import of arms and related material, crude oil and petroleum products)— (i) in the heading, “, crude oil and petroleum products”; (ii) paragraph (1)(b); (l) in regulation 37 (acquisition of military goods and technology, crude oil and petroleum products)— (i) in the heading, “, crude oil and petroleum products”; (ii) paragraph (2)(a); (m) in regulation 40 (prohibitions relating to the associated provision of financial services and funds), paragraph (1)(d); (n) regulation 41 (bank notes or coinage); (o) regulation 47 (electricity production); (p) Part 6 (aircraft); (q) regulation 56 (exceptions relating to insurance and reinsurance services); (r) in regulation 57 (exceptions relating to petroleum products), paragraphs (3)(b) to (d) and (4); (s) regulation 59 (aircraft: exceptions from prohibitions); (t) in regulation 59A(2) (exception for authorised conduct in a relevant country), in the definition of “relevant prohibition”, sub-paragraphs (b), (c) and (e); (u) regulation 63 (aircraft licences); (v) regulation 67 (aircraft: licensing offences); (w) in regulation 84(3B) (trade enforcement: application of CEMA), sub-paragraphs (a) to (i) and (p); (x) in regulation 88(2) (exercise of maritime enforcement powers), sub-paragraphs (2)(c) and (f); (y) Regulation 94 (directions under Part 6); (z) in Schedule 2 (definitions of goods subject to certain trade prohibitions), paragraphs 2 to 5; z1 in Schedule 6 (Treasury licences: purposes)— (i) paragraph 13 (Chemical Weapons Convention); (ii) paragraph 16 (Central and Commercial Banks of Syria); and (iii) paragraph 17 (assisting the civilian population in Syria).
This section lists numerous provisions from the 2019 Syria (Sanctions) (EU Exit) Regulations that are being removed.
These removals reflect a reduction in the scope of sanctions and are principally focused on sectors such as finance, insurance, trade, and the aviation industry.
- Amendment to the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 In the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024, in regulation 30 (aircraft sanctions regulations and shipping sanctions regulations: application of Chapter 1 of Part 2 of Serious Organised Crime and Police Act 2005), omit paragraph (d).
A consequential amendment is made to the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 to remove paragraph (d) of regulation 30, reflecting changes made by the current regulations.
This underscores the removal of some sanctions relating to the aviation sector.