About General License No. 25

Updated May 29, 2025

On May 23, OFAC released General License No. 25 under its Syria Sanctions Regulations. GL25 exempts two categories of transactions from sanctions. The first category covers transactions which would’ve been blocked solely because they took place within Syria. The second group includes transactions with specific entities, like the Government of Syria, businesses which it owns, and some Syrian financial institutions. However, many targeted sanctions in Syria remain, particularly the separate regulations that focus on “external actors” and others who “threaten the peace, security, stability, or territorial integrity of Syria.”

GL25 builds on the exemptions provided by General License No.24 and broadens their application. While GL24 permitted transactions with humanitarian purposes with many of these same actors, GL25 applies the exemption to non-humanitarian transactions as well. This broader reach creates new opportunities for grantmakers – the inclusion of an exemption for banks is likely to provide more financial pathways for getting funding to Syria-based charitable projects. By removing the geographical block on transactions, it can also help reduce the compliance burden on grantmakers and financial institutions. Notably, unlike GL24, GL25 does not include an expiry date.

The lifespan of GL25 will almost certainly be contingent on the government in Syria, which is under pressure from the U.S., EU, and others to implement and sustain good-governance reforms as it weathers short-term challenges with stability following the fall of the Assad regime. If GL25 remains in effect for an extended period of time, it will permit sustained funding through open banking pathways and reduced compliance burdens. This applies to not just humanitarian organizations and financial institutions, but also development initiatives and business investments. Ultimately these OFAC General Licenses and accompanying guidance make it easier to support Syria’s recovery at scale.

For grantmakers seeking to apply GL25 to their work, we recommend a proactive, risk-based approach. Our team of experts at CAF America will review and track any advised grants to Syria to ensure they align with the permissions outlined in GL25 – particularly verifying that any counterparties or partners are not subject to separate sanctions under the Syria-Related Sanctions Regulations. Charities based in Syria will then undergo CAF America’s thorough due diligence process to ensure the gift complies with all other relevant laws and regulations.

To facilitate learning and peer exchange, we also encourage grantmakers to share their experiences navigating these pathways. CAF America will continue to provide critical sanctions updates on the Syrian situation through our various communications platforms. These stories will serve as guideposts for other donors committed to supporting Syrian aid, helping them learn best practices while maintaining compliance and minimizing risk.

Please contact relief@cafamerica.org with any questions.

About General License No. 24

Originally published February 3, 2025

In the midst of Syria’s turbulent political and humanitarian challenges, a new window of opportunity has opened for donors and international charities to provide much-needed aid. On January 6th, 2025, the Office of Foreign Assets Control (OFAC) announced General License No. 24, introducing specific exemptions to sanctions targeting Syria. These exemptions cover certain types of transactions under three sanctions regimes: Syrian Sanctions Regulations, Global Terrorism Sanctions Regulations, and Foreign Terrorist Organizations Sanctions Regulations. The license is temporary and will expire July 7, 2025 if it is not renewed. This announcement is especially significant for those committed to supporting relief efforts and fostering stability in a region where giving has long been hindered by complex legal and regulatory barriers.

What Is General License No. 24?

OFAC released this license amid new interim governance in Syria after the fall of Bashar al-Assad’s regime. Its exemptions are targeted toward transactions that provide continuity of services and governance for the Syrian people. There are three groupings of permitted transactions under the license:

1. Transactions involving Syria’s governing institutions;
2. Those that support energy access to or within (but not from) Syria; and
3. Personal remittances to Syria.

As noted above, these exemptions apply to existing Syria Sanctions, as well as both Global Terror and Foreign Terrorist Organization sanctions lists. Notably, General License No. 24 does not mention a separate but related grouping of Syria-Related Sanctions, which are based on separate regulations from the ones cited in the license.

Implications for Philanthropy in Syria

Grantmaking in Syria is complicated by both comprehensive sanctions (which block most transactions within its borders) and targeted sanctions (which prohibit transactions with specified entities like individuals, groups, or institutions). Even if a transaction were to fit one of OFAC’s permitted exemptions above, it is still important to know why it would have been blocked in the first place. This is because the general license applies to OFAC regulations, transactions with designated Foreign Terror Organizations (FTOs) can still run afoul of laws prohibiting “material support” for such groups. These are separate from sanctions regulations and are enforced separately, by the Department of Justice.

At the moment, it is unclear if — or when — philanthropic contributions could be subject to Material Support enforcement, if they were otherwise permitted by OFAC exemptions. It is worth noting that HTS, the group leading Syria’s interim government, is still listed as an FTO. This being the case, it is also possible financial institutions will seek to avoid such transactions to reduce their own exposure to enforcement risks.

But this does not mean it is impossible to give in Syria. There are other, pre-existing licenses for humanitarian purposes which have been included in Syria Sanctions regulations. Indeed, many international nonprofits and NGOs have longstanding humanitarian aid programs in the country, and which are valid for US charitable donations. While the legal landscape remains complicated, careful validation procedures can ensure that philanthropy in Syria happens in a safe and compliant manner.

Looking Ahead

There are many unknowns for philanthropy in Syria, both pertaining to the country’s political future and any sanctions exemptions. The future of philanthropic giving in Syria remains uncertain. General License No. 24 provides a six-month window, during which the U.S. government will evaluate the effectiveness and risks of these exemptions. The new administration will determine whether to extend, modify, or terminate the license, while also reassessing HTS’s terrorist designation. However, similar to expiration of the previous, earthquake-related General License No. 23, even if this license expires, other humanitarian exemptions remain in place to support aid efforts in Syria. There are other humanitarian exemptions in place should General License No.24 expire.