by: Karam Shaar and Benjamin Feve
Summary
General License 24 (GL24) is a positive development, providing limited relief by enabling private, non-commercial transactions and addressing urgent energy needs in Syria. However, it falls short of fostering long-term recovery and investment, as it excludes provisions for broader economic engagement and reconstruction efforts. A more effective approach would involve lifting unilateral sanctions in exchange for clear commitments from Syria’s new authorities, with the potential for further sanctions relief with respect to terrorism-related sanctions contingent upon measurable deliverables over time.
Background
Since the onset of the Syrian conflict in 2011, opponents of the Assad regime relied heavily on sanctions as a tool to exert pressure on Damascus. These measures, imposed primarily by Western countries and some of their allies, have targeted key sectors of the Syrian economy, such as oil, banking, and trade, alongside individual sanctions aimed at regime-affiliated elites. The goal was to restrict Assad’s ability to fund repression and compel his regime toward a political settlement in line with UN Security Council Resolution 2254. While sanctions disrupted regime activities and reduced revenues, they also entrenched Assad’s power by fostering a war economy and empowering loyalist networks, exacerbating civilian suffering in the process.
The sanctions regimes expanded further with counter-terrorism measures focusing on groups like HTS, designated under the UN ISIL (Da’esh) and Al-Qaeda Sanctions framework as well as unilaterally (e.g., through the US listing of HTS as a Foreign Terrorist Organization (FTO)). These measures aim to isolate HTS leaders and entities tied to terrorism, including Syria’s de facto leader, Ahmad al-Sharaa (formerly Abu Mohammad al-Jolani). Although narrower in scope, counter-terrorism sanctions have created operational challenges for NGOs and humanitarian actors, as the fear of breaching these regulations has deterred engagement in affected areas.
The collapse of the Assad regime on 8 December 2024, has drastically altered the political and economic landscape in Syria. With the justification for broad sectoral sanctions eroding, questions have emerged about the role of sanctions in post-Assad Syria. While they remain a tool for accountability, these measures now risk obstructing recovery, deepening economic hardship, and hindering political stabilization. This shifting context underscores the need for a recalibrated approach to sanctions, balancing humanitarian relief with the imperative for reconstruction and recovery.
What is General License 24?
General License No. 24 (GL24), issued by the US Treasury’s Office of Foreign Assets Control (OFAC) on 6 January 2025, is a targeted measure to adapt the US sanctions framework to Syria’s evolving political and humanitarian landscape. Its primary purpose is to authorize specific transactions related to energy, personal remittances, and governing institutions following 8 December 2024, to alleviate humanitarian and public service provision.
These exemptions extend to three sanctions programmes related, directly or indirectly to Syria: Syrian Sanctions Regulations (SySR), the Global Terrorism Sanctions Regulations (GTSR), and the Foreign Terrorist Organizations Sanctions Regulations (FTOSR). The SySR make up the sanctions related to the former Assad regime, while GTSR and FTOSR more specifically target HTS and its members, including Syria’s de-facto leader Ahmad Al-Sharaa, under his nom de guerre Abu Mohammad al-Jolani, and newly appointed figures like Anas Khattab, the head of the Syrian intelligence services.
Impact of GL24
In the immediate aftermath of GL24 being issued, two key developments highlighted its immediate positive impact. First, the license facilitated the deployment of two electricity-generating ships from Türkiye and Qatar, bringing an additional 800 megawatts (MW) to Syria’s grid. According to Khaled Abu Di, Director-General of the Public Establishment for Electricity Transmission and Distribution, this increase is significant and will nearly double the country’s existing electricity capacity and improve access for citizens by approximately 50%. Prior to GL24, such a development would not have been possible, at least due to the Caesar Act, as showcased by the international agreements involving Egypt over the provision of electricity and gas to Syria and Lebanon that had stalled because of Caesar-related sanctions. As such, it would not be surprising to see similar developments taking place in the coming days, with countries that have shown signs of support for Syria’s emerging government, such as Saudi Arabia.
Second, Qatar announced its intention to fund a substantial 400% increase in public sector wages and compensation in Syria. This move was made possible by the provisions of GL24, which exempted “transactions with governing institutions” from sanctions. While the implementation faced delays due to discrepancies in workforce data according to the caretaker Minister of Finance Mohammad Abazid, it is likely that securing adequate funding, estimated at $120 million, was another significant obstacle to implementation. Today, the Qatari announcement again exemplifies how the license has enabled partial targeted economic relief.
Strengths
GL24 represents a commendable step forward in adapting sanctions policy to the realities of post-Assad Syria. One of its primary strengths lies in its ability to address critical humanitarian and infrastructure challenges by facilitating energy provision. The authorization of transactions related to energy resources and the exemption from sanctions of certain transactions with governing institutions have already led to political commitments by particularly regional actors mentioned above, though they have yet to materialize as of 11 January 2025.
GL24 also demonstrated a significant level of pragmatism and agility by the American administration. Its swift issuance—within just four weeks—shows an urgency and adaptability often absent in bureaucratic decision-making, especially those related to sanctions. Moreover, this approach has also sent positive signals to international partners, setting an example of how sanctions can be refined to meet evolving needs. As a result, this decision can also encourage other stakeholders, especially in Europe, to consider similar measures. At the same time, a positive signal was also sent to the authorities in Damascus, demonstrating that the international community is willing to engage pragmatically with the new leadership under certain conditions.
Weaknesses
Despite its strengths, GL24 falls short in addressing several critical needs. While it focuses on maintaining basic services, it does little to facilitate broader reconstruction or attract new investments, as these remain prohibited under existing sanctions. Additionally, although the License permits remittances to flow through official channels, including the Central Bank of Syria, this provision addresses an issue that is already partly resolved. Remittances to Syria have long been exempt from sanctions under US Federal Code 31 CFR § 542.512 and have continued to flow largely through informal systems like hawala operators, which remain the preferred method due to their efficiency and reach.
However, while hawala facilitates seamless remittance flows, its informal nature poses compliance challenges with the Treasury’s Financial Crimes Enforcement Network (FinCEN) regulations, effectively rendering it illegal in practice. By easing the sanctions on the banking sector, GL24 could potentially shift some transactions into formal channels, enhancing visibility and the ability to apply anti-money laundering and counter-terrorism financing by competent authorities in the sender and recipient countries.
Another key weakness of GL24 lies in the unclear boundary between what can be considered as support for state institutions headed by HTS members and providing direct support to HTS as an organization, which remains criminally liable under their FTO designation. While GL24 permits funding state institutions for salaries and operational needs, ensuring that funds do not benefit HTS as an entity presents practical challenges. Due to inter-state understandings, the License makes state intervention easier, such as is the case with Qatar reportedly ready to fund the public sector salary increase. However, it would be more difficult for NGOs or private individuals to conduct such operations, fearing liability if funds are later diverted to HTS due to inadequate oversight or negligence.
The six-month time limit on the license is also problematic, as it discourages organizations and businesses from initiating projects due to uncertainty about its renewal, mirroring issues seen with previous time-bound licenses.
Another significant issue with GL24 is the lack of alignment among US government agencies, which undermines its effectiveness. Since GL24 does not exempt individuals from compliance with other laws or regulations, exports of petroleum or other commodities to Syria may still require additional authorization from the Department of Commerce under the Export Administration Regulations, creating confusion and operational barriers to effectively implementing GL24.
The broader political context further complicates the License’s impact. The Biden administration appears cautious, aiming to implement reforms without overly constraining a potential future, more hawkish administration. Figures like Joel Rayburn—which voices in Washington see as a potential candidate for the position of Deputy Assistant Secretary of State for Near Eastern Affairs overseeing the Levant and Syria—still remain overtly hostile to HTS and its leadership. This resistance, combined with the likelihood of increased scrutiny under a future administration, raises concerns about the durability of such short-term and partial policy adjustments.