Syria -- Regulatory Status Regulatory Overview

Executive Summary

• There is no specific legal framework for cryptocurrency or digital assets in Syria; the provided sources contain zero references to cryptocurrency, digital assets, virtual currency, blockchain, or related terms. Federal Register :: Termination of the Designation of Syria for Temporary Protected Status
• No Syrian regulatory authority is identified in these sources as having jurisdiction over digital assets, and no licensing or registration regime for crypto businesses exists under the materials reviewed. Temporary Protected Status Designated Country: Syria | USCIS
• The only authorities mentioned are U.S. agencies (OFAC, USCIS, DHS) addressing sanctions and immigration status, which do not constitute a domestic Syrian crypto regulatory framework. Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control
• The practical reality is that Syria's regulatory landscape is defined by international sanctions relief and post-conflict transition, with no evidence of any crypto licensing activity or digital asset supervision. Federal Register :: Syrian Sanctions Regulations
• Businesses considering crypto operations in Syria face an absence of domestic law, meaning any activity would be governed by general financial and commercial statutes not addressed in these sources. Federal Register :: Amendment to the Syria-Related Sanctions Regulations

Regulatory Framework

• The sources provided relate exclusively to U.S. legal actions concerning Syria—specifically the termination of Temporary Protected Status (TPS) and the revocation of comprehensive sanctions—not to any Syrian domestic regulatory framework for financial services or digital assets. Federal Register :: Termination of the Designation of Syria for Temporary Protected Status
• The U.S. Department of Homeland Security (DHS) and U.S. Citizenship and Immigration Services (USCIS) terminated Syria's TPS designation effective November 21, 2025, pursuant to INA section 244(b)(3)(B), 8 U.S.C. 1254a(b)(3)(B), after determining Syria no longer met the conditions for designation. Federal Register :: Termination of the Designation of Syria for Temporary Protected Status
• The U.S. Supreme Court in Mullin v. Doe, 609 U.S. ____ (2026), issued a favorable decision concerning TPS terminations, and the Syria TPS designation was terminated effective July 27, 2026. Temporary Protected Status Designated Country: Syria | USCIS
• The Secretary of Homeland Security determined that Syria no longer continues to meet the conditions for TPS designation after reviewing country conditions and consulting with appropriate U.S. Government agencies, with the designation set to expire September 30, 2025. Federal Register :: Termination of the Designation of Syria for Temporary Protected Status
• The U.S. Treasury Department's Office of Foreign Assets Control (OFAC) removed the Syrian Sanctions Regulations, 31 CFR part 542, from the Code of Federal Regulations on August 26, 2025, following termination of the underlying national emergency. Federal Register :: Syrian Sanctions Regulations
• President Biden issued Executive Order 14312 on June 30, 2025, "Providing for the Revocation of Syria Sanctions," which terminated the national emergency underpinning the Syrian Sanctions Regulations effective July 1, 2025. Federal Register :: Syrian Sanctions Regulations
• OFAC amended the Syria-Related Sanctions Regulations, 31 CFR part 569, on September 25, 2025, renaming them the "Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations" (PAARSSR), implementing Executive Orders 14142 (January 15, 2025) and 14312 (June 30, 2025). Federal Register :: Amendment to the Syria-Related Sanctions Regulations
• OFAC no longer maintains comprehensive sanctions on Syria or blocking sanctions on the Government of Syria; instead, it maintains list-based sanctions on former Syrian President Bashar al-Assad, his associates, human rights abusers, Captagon traffickers, and persons linked to proliferation activities. Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control
• The Caesar Syria Civilian Protection Act of 2019 was repealed on December 18, 2025, when President Trump signed the National Defense Authorization Act for Fiscal Year 2026. Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control
• The determination of Syria as a State Sponsor of Terrorism was rescinded on August 24, 2026, removing Syria from prohibitions under the Terrorism List Governments Sanctions Regulations, 31 CFR part 596. Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control
• None of the sources reference FATF or Moneyval assessments of Syria, nor do they identify any Syrian government body charged with financial regulation or digital asset oversight. Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control
• The Executive Order 14312 found that circumstances related to the former regime of Bashar al-Assad had been transformed by developments in the six months preceding June 30, 2025, including positive actions taken by the new Syrian government under President Ahmed al-Sharaa. Federal Register :: Syrian Sanctions Regulations

Licensing Requirements

• Zero entities have been licensed to conduct cryptocurrency or digital asset activity in Syria according to the provided sources, and no Syrian licensing authority is identified anywhere in the materials. Federal Register :: Termination of the Designation of Syria for Temporary Protected Status
• No Syrian law, decree, circular, or regulation requiring a license or registration for crypto-related business activities (exchange, wallet provision, custody, mining, or payment processing) is referenced in any of the provided source documents. Temporary Protected Status Designated Country: Syria | USCIS
• The only licensing-related mechanism mentioned is OFAC's specific licensing process for otherwise prohibited transactions under U.S. sanctions, which is a U.S. requirement, not a Syrian one. Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control
• OFAC issued a General License on May 23, 2025, authorizing transactions previously prohibited by the Syrian Sanctions Regulations or involving certain blocked persons, but this is a U.S. authorization with no bearing on any Syrian domestic licensing regime. Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control
• No capital requirements, application timelines, or structural prerequisites for any Syrian crypto license appear anywhere in the source materials because no such licensing framework exists in the record. Federal Register :: Syrian Sanctions Regulations
• The PAARSSR (31 CFR part 569) contains licensing provisions, but these relate to U.S. sanctions compliance (e.g., licenses for legal fees and costs, statements of licensing policy for telecommunications, agriculture, and petroleum sectors), not to any Syrian digital asset authorization. Federal Register :: Amendment to the Syria-Related Sanctions Regulations
• U.S. persons are not broadly prohibited from engaging in transactions with respect to Syria or the Government of Syria that were previously prohibited solely by the Syrian Sanctions Regulations, which may affect the practical ability of foreign firms to operate in Syria but does not constitute Syrian licensing. Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control

AML/KYC Requirements

• No anti-money laundering (AML) or know-your-customer (KYC) requirements specific to cryptocurrency or digital asset businesses in Syria are mentioned anywhere in the provided sources. Federal Register :: Termination of the Designation of Syria for Temporary Protected Status
• The sources do not reference any Syrian customer due diligence (CDD), enhanced due diligence (EDD), suspicious transaction reporting (STR), record retention, beneficial ownership, or politically exposed person (PEP) screening obligations for virtual asset service providers. Temporary Protected Status Designated Country: Syria | USCIS
• The only sanctions-related screening obligations referenced are those imposed by OFAC under U.S. law, which apply to U.S. persons and persons subject to U.S. jurisdiction, not as a matter of Syrian domestic law. Federal Register :: Syrian Sanctions Regulations
• OFAC maintains a List of Specially Designated Nationals and Blocked Persons (SDN List) on which persons designated pursuant to the PAARSSR may be found, but this is a U.S. compliance tool, not a Syrian AML/KYC regime. Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control
• Section 4(a) of E.O. 14312 expands the scope of the national emergency declared in E.O. 13894 to address war crimes, human rights violations, and narcotics trafficking in Syria during the Assad regime; these sanctions target designated persons but do not establish any AML framework for crypto businesses in Syria. Federal Register :: Amendment to the Syria-Related Sanctions Regulations
• OFAC has published sanctions advisories on evasion tactics used by Syria, including risks related to petroleum shipments involving Iran and Syria (September 11, 2024) and guidance on humanitarian assistance (August 8, 2023), but none of these address crypto AML/KYC requirements. Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control

Enforcement Actions

• The provided sources reference no enforcement actions taken by any Syrian authority against cryptocurrency or digital asset businesses; no entity name, violation, outcome, or date involving crypto enforcement in Syria appears in the materials. Federal Register :: Termination of the Designation of Syria for Temporary Protected Status
• The revocation of sanctions on July 1, 2025, does not affect past, present, or future OFAC enforcement investigations or actions associated with any apparent violations of the Syrian Sanctions Regulations that occurred prior to July 1, 2025, but this concerns U.S. enforcement, not Syrian crypto enforcement. Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control
• Similarly, revocation of the State Sponsor of Terrorism designation on August 24, 2026, does not affect OFAC enforcement investigations of Terrorism List Governments Sanctions Regulations violations prior to that date, again a U.S. enforcement matter. Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control
• The sources describe the removal of persons designated solely pursuant to revoked Executive Orders from the SDN List and the unblocking of their property, reflecting the reversal of prior U.S. sanctions designations, not any Syrian crypto enforcement case. Federal Register :: Syrian Sanctions Regulations
• No penalties, fines, arrests, or prosecutions involving crypto activities in Syria are documented in any of the six provided source materials. Federal Register :: Amendment to the Syria-Related Sanctions Regulations

Tax Treatment

• No tax guidance has been issued for virtual assets in Syria, according to the provided sources, which contain zero references to capital gains tax, income tax, VAT, or any other taxation of cryptocurrency or digital assets in Syria. Federal Register :: Termination of the Designation of Syria for Temporary Protected Status
• None of the six source documents address how crypto gains would be treated under Syrian tax law, whether as income, capital gains, or otherwise. Temporary Protected Status Designated Country: Syria | USCIS
• The sources discuss immigration benefits and U.S. sanctions, not fiscal policy; no Syrian tax authority, tax law, or tax circular is named or referenced anywhere in the materials. Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control
• Given the absence of any Syrian tax framework for virtual assets in the record, businesses cannot rely on these sources for any guidance on how crypto transactions would be taxed in Syria. Federal Register :: Syrian Sanctions Regulations

Key Gaps & Risks

• The most significant gap is the complete absence of any Syrian domestic legal framework for cryptocurrency or digital assets; the sources provided are exclusively U.S. documents concerning sanctions relief and TPS termination, none of which establish or even mention a Syrian crypto regime. Federal Register :: Termination of the Designation of Syria for Temporary Protected Status
• No Syrian regulatory body with authority over digital assets is identified in any source; the only authorities named (USCIS, DHS, OFAC) are U.S. agencies whose actions affect Syria indirectly through sanctions and immigration policies. Temporary Protected Status Designated Country: Syria | USCIS
• A business operating in the crypto space in Syria faces legal uncertainty because there are no licensing procedures, AML/KYC obligations, or tax rules specific to virtual assets in the record, leaving firms without any compliance roadmap. Federal Register :: Syrian Sanctions Regulations
• Comprehensive U.S. sanctions on Syria were lifted as of July 1, 2025, and the State Sponsor of Terrorism designation was rescinded on August 24, 2026, which reduces U.S. sanctions risk; however, list-based sanctions remain on specific individuals (Assad, his associates, Captagon traffickers, human rights abusers), and U.S. persons must still screen against the SDN List. Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control
• The PAARSSR maintains sanctions on persons designated under E.O. 13894 as further amended; individuals previously sanctioned under revoked E.O.s were redesignated under this authority, meaning due diligence requires checking OFAC's SDN List for any Syria-related business counterparty. Federal Register :: Amendment to the Syria-Related Sanctions Regulations
• Hay'at Tahrir al-Sham was removed as a Specially Designated Global Terrorist organization from the SDN List on August 24, 2026, but other terrorist organizations and Iran-linked entities remain sanctioned, creating a complex counterparty risk environment for any business in Syria. Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control
• The sanctions landscape is in flux: E.O. 14312 states that sanctions were removed "without providing relief to the so-called Islamic State of Iraq and Syria or other terrorist organizations, human rights abusers, those linked to chemical weapons or proliferation-related activities," meaning any crypto business could inadvertently facilitate transactions involving sanctioned parties absent robust compliance. Federal Register :: Syrian Sanctions Regulations
• The practical reality is that Syria is in a post-conflict transition under President Ahmed al-Sharaa with a transformed sanctions environment, but no evidence in these sources indicates that the new government has enacted any crypto-specific laws or established a regulator, leaving a legal vacuum for digital asset businesses. Federal Register :: Amendment to the Syria-Related Sanctions Regulations

Sources

• Federal Register :: Termination of the Designation of Syria for Temporary Protected Status
• Temporary Protected Status Designated Country: Syria | USCIS
• Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control
• Federal Register :: Syrian Sanctions Regulations
• Federal Register :: Amendment to the Syria-Related Sanctions Regulations
• Syria: Transition and U.S. Policy | Congress.gov | Library of Congress
• Syria Sanctions
• Sanctions and Export Controls Relief for Syria Updated August 2026 Overview
• Frequently Asked Questions - Newly Added | Office of Foreign Assets Control
• Syria Sanctions - United States Department of State