Caesar Act: What Has Actually Changed?
The 180-day U.S. suspension of some Caesar Act secondary sanctions (announced in – November 2025) reduces the risk that non-U.S. persons will be subject to new U.S. secondary sanctions for many Syria-related commercial/reconstruction activities, but important U.S., UK and EU sanctions risks remain. These include:
continuing U.S. primary-sanctions exposure (SDN listings and new designations under other authorities),
U.S. export-control and ITAR restrictions,
explicit carve-outs for dealings involving Russia or Iran,
retained targeted designations in all three jurisdictions, and
jurisdictional/financial-clearing risks (e.g. USD clearing, U.S. persons).
Detailed below Ferrer Consultancy Services has summarised the substantial risks by jurisdiction and give a short operational checklist you can use right away.
What the U.S. action actually does
The State Department/Treasury action announced a 180-day suspension/waiver of the imposition of certain Caesar Act secondary sanctions (i.e., the penalties the U.S. could apply to foreign persons for doing business in Syria). That suspension is temporary and must be renewed or allowed to lapse. The suspension does not include US secondary sanctions imposed on Russia or Iran, these are still fully enforced.
Remaining U.S. sanctions risks
Designations and primary sanctions remain. OFAC continues to enforce designations made under other authorities (notably E.O. 13894 and other authorities). Persons (incl. Assad, certain associates, human-rights abusers, Captagon traffickers and other destabilising actors) remain designated and blocked where they are listed under those authorities. Dealing with listed persons remains prohibited.
Export controls (EAR/ITAR) still apply U.S. Commerce (EAR) and State (ITAR) controls on exports/re-exports of dual-use, military and certain technology or software remain in force and can require licenses or be denied these are separate from Caesar Act secondary sanctions.
Transactions involving Russia or Iran (and Russian/ Iranian-origin goods/tech/funds) are excluded from the suspension. Public reporting and the Treasury/State text make clear that the suspension does not cover transactions involving Russia or Iran (or transfers of Russian/ Iranian-origin items). That means secondary-sanctions risk remains high for any Syria work that touches Russian or Iranian persons, supply chains, or origin goods/technology.
Retroactive or prior-conduct enforcement & other U.S. sanctions OFAC can still investigate and pursue apparent violations that occurred before the suspension; other U.S. sanctions programs (terrorism, proliferation, narcotics) still apply.
Jurisdictional footprints USD clearing and U.S. persons Use of U.S. banks, USD clearing, or involvement of U.S. persons (employees, branches, subsidiaries) can pull a transaction into U.S. jurisdiction and revive exposure even where secondary sanctions are suspended.
Remaining EU risks
The EU had already suspended/lifted many macroeconomic sectoral measures in 2025 but retained targeted measures in a narrower list. The EU FAQ and legal acts make clear that while many measures were eased (to facilitate reconstruction), individual asset freezes and travel bans on listed persons can remain and export controls/dual-use rules continue to apply depending on item and end-use. The EU also retains its own rules on trade in arms, dual-use, and sanctions related to terrorism/proliferation. Check the EU FAQ/Legal acts for the specific listings and the measures actually lifted vs retained: finance.ec.europa.eu
Remaining UK risks
The UK has similarly eased sectoral measures and delisted a number of Syrian state entities in 2025, but the UK retains targeted listings (asset freezes, travel bans) and export-control/dual-use rules. OFSI enforcement of UK financial sanctions and the UK Syria sanctions regulations remain applicable to U.K. persons and entities. The UK guidance and statutory instruments set out what was removed vs what stayed: OFSI Syria regulations
Practical risk checklist (what to do now)
Screen counterparties/beneficiaries against: OFAC SDN/PAARSS and E.O. 13894 lists, EU consolidated list, UK Consolidated List (UK Sanctions List by 28 January 2026). Maintain live screening because designations can be added.
Exclude Russia/Iran exposure: avoid suppliers, finance, logistics or inputs of Russian or Iranian origin (supply-chains are explicitly excluded from the suspension).
Check export control classification and license requirements (EAR/ITAR for U.S. origin items; EU/UK dual-use controls for relevant goods/tech). Don’t assume civilian end-use removes controls for dual-use items.
Document reliance on licenses/GL25 or other U.S. authorisations and retain legal opinions where transactions rely on the U.S. general license/waiver remember the waiver is temporary (180 days) and may change.
Plan for volatility reputational and compliance risk remains high; some banks and insurers may not transact even when legal risk is reduced.
Quick summary of the highest-priority lingering risks
Dealing with designated individuals/entities (still prohibited everywhere).
Transactions involving Russia or Iran (explicit exclusion from the suspension).
U.S. export controls and ITAR (separate regimes still in force).
Jurisdictional exposure via U.S. persons / USD clearing (can trigger U.S. authority).
EU/UK targeted listings and national measures (asset freezes, travel bans, export controls).
Author: Manmeet Lotay - Global Sanctions Advisor - Ferrer Consultancy Services
Ferrer Consultancy Services empowers clients to stay ahead of sanctions risk through proactive, data-driven controls that build resilience and agility in an evolving global landscape. By enhancing sanctions frameworks and implementing proactive risk mitigation strategies, Ferrer Consultancy Services enables organisations to anticipate and manage sanctions exposure - not just react to it - ensuring confidence in a constantly shifting regulatory ecosystem.
If you're ready to turn compliance into a competitive advantage - contact us today to learn how we can help your organisation proactively manage and mitigate sanctions risks.