Syria’s State Sponsorship of Terrorism Designation

Syria’s State Sponsorship of Terrorism Designation: Implications and Pathways for Lifting 

Vittorio Maresca di Serracapriola and Karam Shaar

Summary

The US has designated Syria as a State Sponsor of Acts of International Terrorism (SST) since 1979, initially due to the Assad regime’s support for Palestinian non-state actors and armed groups. This designation was later reinforced by Syria’s direct involvement in planning attacks—such as the 1986 plot to bomb an El Al airliner—and its backing of Hezbollah, the Lebanese militia-cum-political party. With the Assad regime now ousted, Syria formally meets the legal criteria for rescinding its SST designation: a fundamental change in leadership and policy; a cessation of support for international terrorism—particularly following its recent break with Hezbollah; and formal assurances that it will not support terrorism in the future, including cooperation on counterterrorism with the US. These conditions enable the president to certify and report to Congress the intent to remove Syria from the SST list.

Introduction

On 29 December 1979, the US designated Syria as an SST—the first time it had ever used this designation. Washington based its decision on Syria’s support for armed Palestinian factions and other non-state actors opposing Israel, which it classified as terrorism. 

Since then, the US has consistently renewed the designation, citing ongoing ties between Damascus and non-state actors it considers terrorist organizations. But with the Assad regime ousted, and with President Donald Trump now calling for a “cessation of sanctions” to give Syria “a chance at greatness,” the groundwork is laid for a broader reassessment. 

Under US law, the Secretary of State may designate a country as an SST if its government repeatedly provides support for acts of international terrorism. Once listed, a country remains designated until the secretary formally rescinds the label through a defined legal process. Beyond legal thresholds, the label carries a reputational weight that shapes how other governments, banks, and businesses engage—or more often, disengage—with designated states. 

Trump’s recent statement may not by itself trigger delisting. But it coincided with a statutory deadline on 15 May,¹ which offered a procedural window for reassessment. By 15 May, the State Department must identify governments “not cooperating fully” with US counterterrorism efforts—a distinct designation that may nonetheless feed into wider internal debates about the SST label.^2,3 While the SST designation and the cooperation on counterterrorism certification are legally distinct⁴, a reassessment of Syria’s cooperation on counterterrorism could form part of a wider review of whether the country’s inclusion on the SST list is still justified.

That date has now passed without any formal changes, but key issues remain under consideration: whether Syria, in its current post-Assad configuration, still satisfies the legal criteria for designation; and whether continuing to list Syria serves US strategic interests or merely reflects an outdated policy posture. 

As it stands, the SST list includes just four countries: Syria, Cuba, Iran, and North Korea. Former entries included Iraq, South Yemen, Libya, and Sudan. Lifting Syria’s designation now would mark a significant shift, suggesting that Washington is willing to reorient its policy toward a country it has long treated as a pariah.

How States are Designated 

The US Secretary of State holds broad discretion to designate a foreign state as an SST. This authority, delegated by Congress, requires the secretary to determine that the government in question has “repeatedly provided support for acts of international terrorism.” However, US law does not fully define “international terrorism” in this context, leaving room for interpretation. Other statutes and case law offer general parameters, but the designation process remains flexible by design.

Crucially, the law does not mandate that the secretary designate every government that meets the criteria—nor does it require that countries on the SST list be the world’s most significant supporters of terrorism at any given time. This discretion means that geopolitical interests, domestic political considerations, and broader foreign policy agendas often play a decisive role. The re-designation of Cuba in 2021, based on tenuous terrorism-related evidence, is one such example of how politics can overshadow substance.

​​In Syria’s case, this discretion is now under scrutiny. Since the collapse of Bashar al-Assad’s regime in late 2024, the rationale for Syria’s inclusion on the SST list has become increasingly contested. As the six-month mark since Assad’s ouster approaches, the Trump administration faces mounting pressure from international and Syrian civil society organizations to reevaluate whether maintaining the designation is warranted. 

Legal Mechanisms and Consequences of an SST Designation

Three statutes authorize the Secretary of State to designate a foreign government as an SST for repeatedly providing supports for acts of international terrorism, and to curtail aid or trade to that state as a result: 

• Section 620A of the Foreign Assistance Act of 1961 (FAA’61; 22 USC 2371) prohibits most forms of US aid and foreign assistance to SSTs, including under the Food for Peace Act, Peace Corps Act, or the Export-Import Bank Act.
• Section 40(d) of the Arms Export Control Act of 1976 (AECA’76; 22 USC 2780) prohibits exports, credits, guarantees, other financial assistance, export licensing overseen by the State Department, and general eligibility related to providing munitions. 
• Section 1754(c) of the Export Control Reform Act of 2018 (ECRA’18; 50 USC 4813)⁵ requires validated export licenses—typically presumed denied—for trade in goods or technology that were controlled by the Department of Commerce for national security or foreign policy reasons.

Additionally, although now repealed, Section 6(j)(A) of the Export Administration Act of 1979 (EAA’79; 50 USC 2401–2420) played a crucial role in the designation of the governments of Iran, Sudan, Syria, and North Korea as state sponsors of international terrorism. While the EAA’79 itself is no longer in force, its provisions have been effectively carried forward through Section 1768 of the ECRA’18, meaning earlier SST designations made under the EAA’79 still remain valid and enforceable under current law.

Over time, Congress has revised these statutes to harmonize definitions, clarify the process for adding or removing countries from the list, and enhance congressional oversight. While these laws originally did not create a formal “list” mechanism, they now function together to provide a consistent legal framework for identifying and sanctioning governments that support international terrorism.

Consequences of Designation 

Designating a state as an SST carries significant legal, political, and reputational consequences. For this reason, Washington typically avoids listing countries with which it maintains complex or multifaceted relations. The four currently listed states share a key trait: the US had minimal diplomatic or commercial ties with any of them. In each case, extremely poor bilateral relations preceded the designation, and the listing itself has further deepened the rift.

The SST designation comes with a variety of sanctions, including:

• restrictions on US foreign assistance, including restrictions on foreign aid and support from international financial institutions
• preferential trade benefits restrictions
• a ban on defense-related exports and sales

• export restrictions for dual-use items, such as commercial items with potential military applications⁶.

   

Figure 1: Statutes Authorizing the State Department for SST Designation

While the State Department handles the designation and issues the annual terrorism reports that inform it, implementation falls across different agencies. The Department of Commerce, through the Bureau of Industry and Security,⁸ implements and enforces export controls that restrict the trade of goods, technology, and services to certain countries or entities due to national security, foreign policy, or economic reasons. The Department of the Treasury penalizes individuals or companies that violate the sanctions. 

Countries on the SST list lose access to most foreign aid, preferential trade benefits, and support from international financial institutions. The ECRA’18 requires validated licenses for nearly all exports to SST countries, except for humanitarian goods such as food, medicine, and informational materials authorized by public law. 

Being listed as an SST also restricts bilateral assistance in annual foreign assistance appropriations acts, as required most recently in Section 527 of the Foreign Operations, Export Financing and Related Programs Appropriations Act of 2005. In other words, agencies like the US Agency for International Development are barred from funding most projects or programs in Syria unless the president grants a waiver. 

Moreover, Section 502 of the Trade Act of 1974 bars SST countries from participating in the Generalized System of Preferences (GSP)—a US trade program that grants duty-free access to the American market for thousands of products exported by developing countries. In Syria’s case, exclusion from the GSP further removes economic incentives for recovery and trade revival in the post-Assad era. 

Section 620A(a) of the FAA’61 further blocks development aid, Peace Corps programs, nonemergency agricultural support, and Export-Import Bank financing. However, this Act authorizes the president to waive certain restrictions if doing so is justified on national security or humanitarian grounds.⁹

Congress can also override restrictions by including provisions in annual appropriations bills that allow aid “notwithstanding any other provision of law”—a mechanism that can be used to maintain assistance flows to countries under sanction. 

Additionally, Section 40(d) of the AECA’76 prohibits the export of munitions to governments that support terrorism. 

Section 40A(d) of the AECA’76 also allows the president to certify annually—by 15 May—that a country is not cooperating with US counterterrorism efforts.¹⁰ Syria’s current designation under this section denies it sovereign immunity in US courts for terrorism-related claims, exposing its government to lawsuits and further penalties.

Reputational and Indirect Effects

Beyond legal implications, an SST designation also generates a host of indirect but powerful effects. Because the US typically reserves the label for states it considers global pariahs, the stigma attached to the listing can be stronger than that of other sanctions. US-based businesses and NGOs often assume that any form of engagement is prohibited—even when numerous economic and financial activities remain legal, theoretically leaving the private sector considerable room to operate. 

Foreign firms may also hesitate to engage, fearing exposure to legal action in the US and based upon the potential for onerous fines,¹¹ especially if they operate in American jurisdictions or employ US nationals.¹²

More broadly, both domestic and foreign firms are deterred by the reputational risks associated with conducting business in an SST-designated country, as such associations can attract negative media attention and public scrutiny. An accidental transaction that benefits a sanctioned state could expose a company to serious legal and reputational consequences.

Even when legal avenues exist, the uncertainty and stigma of ties to a US-designated SST are often too great for businesses. The case of Sudan illustrates this well: even after Washington lifted comprehensive economic sanctions in 2017 to encourage private sector engagement, most firms stayed away. The SST designation remained in place until 2020, contributing to a chilling effect that outweighed formal easing measures. US officials reportedly had to send comfort letters to domestic banks, reassuring them that facilitating accounts for the Sudanese Embassy in Washington DC was permitted and supported by the US government. 

Faced with legal ambiguity and high compliance risks, businesses tend to favor cautious approaches, opting out of transactions that could even remotely be construed as linked to an SST-designated state. 

Restrictions on International Financial Institutions

Being on the SST list also blocks US support for international financial institution engagement. Under Section 1621 of the International Financial Institutions Act, if a country is on the SST list, the US must oppose membership in and financial assistance from international financial institutions such as the World Bank, the Asian Development Bank, and the International Monetary Fund (IMF).¹³

Although the US has various means of interrupting prospective loans before they reach the World Bank or IMF Executive Board—for example, by voting at these institutions’ boards, where the US has an important voting share,¹⁴ or by pressuring the managing directors not to advance them—it was not always able and/or willing to do so in the case of Syria.

Even before Assad’s crackdown on the civil uprising in March 2011 and the outbreak of civil war, Syria’s SST designation had limited impact on Syria in terms of World Bank loans to the country. Despite being on the list since 1979, Syria continued to receive World Bank support and investments. In 1981, just two years after its designation as an SST, the World Bank approved a USD 15.6 million loan for a “second education project,” funding vocational training, a basic healthcare program for schoolchildren, and improvements in primary and secondary education. Similarly, in 1985 the World Bank approved a USD 7.5 million loan to boost agricultural productivity by improving farm management practices and extension services.

One possible reason these loans proceeded despite the SST designation is that they fell below the thresholds requiring full IMF Executive Board approval. According to the World Bank’s Directive on Investment Project Financing, smaller projects—often implemented via recipient-executed trust fund grants¹⁵—can be approved at the management level using streamlined processes, reducing the likelihood of US intervention through Board channels.

At present, despite Syria’s SST designation, the World Bank is re-engaging with Syria. In a significant move, Saudi Arabia and Qatar paid off Syria’s outstanding USD 15.5 million debt to the World Bank, helping the war-ravaged country access funding for postwar development and reconstruction.

In a joint statement at the April 2025 Spring Meetings of the World Bank and the IMF in Washington, Saudi Arabia and Qatar stated that “this commitment will pave the way for the World Bank Group to resume support and operations in Syria after a suspension of more than 14 years.” Notably, Syria’s Central Bank governor and finance minister attended the World Bank and IMF meetings for the first time in more than two decades.

The Rationale for Syria’s SST Designation 

Of the three US statutes that authorize the designation of a foreign government as an SST, only the AECA’76 outlines specific objectionable activities. While the AECA’76 does not define “international terrorism” outright, it states that the term includes: “all activities that the Secretary [of State] determines willfully aid or abet the international proliferation of nuclear explosive devices to individuals or groups, willfully aid or abet an individual or groups in acquiring unsafeguarded special nuclear material, or willingly aid or abet the efforts of an individual or group to use, develop, produce, stockpile, or otherwise acquire chemical, biological, or radiological weapons.”¹⁶

None of the relevant statutes clearly define “international terrorism.” However, Section 140 of the Foreign Relations Authorization Act (22 USC 2656f) offers a functional definition for the State Department’s annual reporting. It defines “international terrorism” as “premeditated, politically motivated violence against noncombatant targets by subnational groups or clandestine agents.” It also states that a government supports international terrorism if it knowingly allows or ignores such activities on its territory and is not exempt under the relevant statutes. 

1979: Initial Designation and Direct Involvement

The US has justified Syria’s SST designation by pointing to its longstanding support for groups that Washington deems terrorist organizations. A 1980 report by the US Central Intelligence Agency (CIA) identified Syria as a major supporter of the Palestine Liberation Organization (PLO). The report noted Syria’s increasing role in Palestinian militancy, including its backing of radical elements within the PLO, such as the Popular Front for the Liberation of Palestine (PFLP), the Popular Front for the Liberation of Palestine–General Command (PFLP–GC, a separate group from the PFLP), and the Democratic Front for the Liberation of Palestine. It also documented Syria’s creation of Sa’iqa, whose militant wing, Eagles of the Palestinian Revolution, engaged in terrorist attacks. The CIA further reported that Syrian intelligence services and diplomatic facilities abroad had supported various terrorist campaigns, including against Jordanian officials. 

According to a later report published by the US Department of State, since the 1980s the Syrian government provided safe haven, logistical support, and political cover to groups such as Hamas, the Palestinian Islamic Jihad (PIJ), and the PFLP–GC—all of which maintained offices in Damascus. Although Syrian officials labeled them as “resistance fighters,” the US viewed this support as enabling terrorism.

Syria’s links to terrorism extended beyond tolerance. In the 1980s, Syrian intelligence played a direct role in planning attacks, such as the 1986 plot to bomb an El Al airliner—commonly known as the Hindawi affair—which led several Western nations to cut diplomatic ties with Damascus.

1986: Permissive Environment and Strategic Alliances 

After 1986, Syria scaled back direct involvement in attacks but maintained what US officials described as a permissive environment for terrorist operations. Although Damascus barred groups from launching attacks within Syria or targeting Western nationals, it allowed designated groups to operate on its soil and coordinate regional violence. US intelligence also linked Syria to the 2005 assassination of Lebanese Prime Minister Rafik Hariri—an event that deepened its reputation as an SST. 

From the early 2000s, Syria became a recruitment and transit hub for jihadist volunteers traveling to join the insurgency in Iraq. The Assad regime, while denying direct involvement, tolerated or even facilitated the movement of al-Qaeda-affiliated militants across its borders. These networks later gave rise to ISIS, which would go on to destabilize Syria itself.

Syria has also served for decades as the central conduit for Iranian arms and support to Hezbollah, a US-designated foreign terrorist organization. The Assad regime allowed Iran to move weapons through Syrian territory and offered its own political and military backing to Hezbollah. During Syria’s military presence in Lebanon (1976–2005), Syrian forces turned a blind eye to Hezbollah’s operations. Even after the withdrawal, Syria continued to support the group, as repeatedly noted in State Department reports. 

Throughout the 2010s, the Assad regime continued to justify these alliances, publicly defending Hezbollah, Hamas, and the PIJ as legitimate resistance movements. While labeling its domestic opposition as terrorists, the regime openly celebrated Hezbollah’s intervention in Syria’s civil war, exposing the contradiction at the heart of its rhetoric.

This pattern of behavior—supporting foreign militant groups and undermining US counterterrorism goals—formed the backbone of Syria’s inclusion on the SST list. US officials consistently pointed to Syria’s alliance with Hezbollah and Iran—also listed as an SST state since 1984—as key reasons further entrenching Syria’s position on the list. 

Post-2024: Regime Collapse and Sanctions Lifting 

In December 2024, Syria’s political leadership changed dramatically. The collapse of the Assad regime and the rise of a Hay’at Tahrir al-Sham (HTS)-led administration have introduced a new political calculus. Unlike the Assad regime, the new authorities have publicly broken with Hezbollah and significantly downgraded relations with Iran. HTS has refrained from antagonizing Israel and condemned Iranian-backed militias operating in the region. These moves represent a marked shift away from the alliances that once underpinned Syria’s SST designation.

The evolving context raises questions about the continued pertinence of Syria’s designation as an SST. The original rationale—rooted in both Hafez and then Bashar al-Assad's patronage of Palestinian militia-cum-political parties, Hezbollah, and alignment with Iran—no longer reflects the current Syrian government's stated positions or actions. The Interim Government’s early gestures suggest a departure from the behaviors that warranted the SST label. 

Still, Syria remains on the SST list, in part due to bureaucratic inertia and the absence of a formal reassessment. By 15 May 2025 the State Department was required to submit a legally required report on countries “not cooperating fully” with US counterterrorism efforts—a separate list from the SST designation. Combined with the Trump administration’s announcement on the cessation of sanctions, this statutory deadline could have presented a timely opening to revisit Syria’s status.

The Syrian Interim Government has already responded in writing to a list of US conditions for possible partial sanctions relief, stating that it has complied with most of them and that others require “mutual understandings” with Washington. It also acknowledged “ongoing communication” between Syria’s counterterrorism authorities and US representatives in Amman, Jordan, regarding operations against the Islamic State, and expressed interest in expanding that cooperation. 

The process of reviewing counterterrorism cooperation could have provided momentum for examining whether Syria’s designation still reflects the current reality—or merely perpetuates the legacy of a regime no longer in power.

The SST Removal Process 

SST designations tend to be sticky, in part because the process is politically sensitive and layered with legal hurdles. To initiate removal, the US president must report to Congress and confirm one of two conditions: either (a) the country has undergone a fundamental shift in leadership and policy, stopped supporting terrorism, and committed not to do so in the future; or (b) the country has abstained from supporting terrorism for the past six months and provided future assurances. 

Even then, Congress can block delisting through a joint resolution—although overriding a presidential veto would require a two-thirds majority in both chambers, making such an intervention procedurally possible but politically unlikely.

The three statutes that govern SST designations—the ECRA’18, the FAA’61, and the AECA’76—also provide the formal legal basis for delisting. While each has distinct elements, all three have in common two possible paths for removing a foreign government from designation. 

The first possible option stipulates that the president certifies and reports to Congress that three criteria have been met: 

• the country’s leadership and policies have fundamentally changed
• the government no longer supports international terrorism
• the government has provided assurances that it will not support acts of international terrorism in the future. 

Under the ECRA’18, the president notifies the Speaker of the House, the chairpersons of the House Committees on Foreign Affairs and on Banking, Housing, and Urban Affairs, and the chairpersons of the Senate Committees on Banking, Housing, and Urban Affairs and on Foreign Relations when such changes occur. The FAA’61 and the AECA’76 require the president to notify only the Speaker of the House and the Senate Foreign Relations Committee Chairperson. 

Figure 2: SST Rescission Triggered by Regime Change 

The second option allows a country to exit the SST list after six months of non-terrorist activity, provided the president confirms this and notifies Congress 45 days before the rescission takes effect (as identified in the first option) that the following two criteria have been met: 

• the government concerned has not provided any support for acts of international terrorism during the preceding 6-month period

• the government concerned has provided assurances that it will not support acts of international terrorism in the future. 

   

Figure 3: SST Rescission Triggered by Behavioral Change

There is no reporting requirement to notify Congress that the “clock has started ticking” on the six-month period of changed behavior of the designated government. In previous delisting cases, the State Department has sometimes issued signals that a country’s behavior is under review, but such notifications are not legally mandated beyond the 45-day requirement prior to issuing a rescission. As a result, the clock may begin running without public awareness, as only the final 45-day notice is required. This lack of transparency limits oversight and compresses the window for legislative or civil society engagement, making the SST designations even stickier.

Recent developments in Syria complicate the case for delisting. In early March 2025, reports emerged of extrajudicial executions carried out by military personnel affiliated with the current administration on the western coast. Although these actions do not meet the legal definition of international terrorism—they occur entirely within Syria and involve state forces, whereas terrorism under US law applies exclusively to non-state actors—they reveal a continued reliance on political violence by state-linked forces. This pattern, while distinct from terrorism, sustains perceptions of instability and authoritarianism that might complicate any credible case for Syria’s removal from the SST list. 

Congress plays a formal role in the delisting process through the AECA’76, which is the only statute that explicitly outlines a mechanism for legislative blockage. If the president reports an intent to delist, Congress has a 45-day window to pass a joint resolution prohibiting the move. This power reinforces the notion that delisting remains a high-stakes political decision, not merely a technocratic or legal assessment.

The President’s Authority to Issue Waivers

Each of the three statutes—the ECRA’18, the FAA’61, and the AECA’76—provides the president with the authority to issue waivers. These waivers enable the president to lift specific restrictions tied to the SST designation on a case-by-case basis, following consultation with and reporting to Congress.

Under the ECRA’18, the president can approve validated export licenses for a designated government. To do so, the Secretaries of Commerce and State must notify the House Committee on Foreign Affairs and the Senate Committees on Banking, Housing, and Urban Affairs and on Foreign Relations at least 30 days before issuing each license. The notification must include a detailed report on the items or services to be exported, reexported, or transferred in-country, along with an explanation of why the proposed transfer serves the national interest of the US.¹⁷

Under the AECA’76, the president may waive munitions-related restrictions for a specific transaction if they determine that the transaction is “essential to the national security interests of the United States.” The president must take both of the following actions: 

• consult with the House Foreign Affairs and Senate Foreign Relations Committees 15 days in advance of any such decision 
• submit a detailed report on the transaction—including “the reasons why the proposed transaction is essential to the national security interests of the United States”—to the Speaker of the House, the Chairperson of the House Committee on Foreign Affairs, and the Chairperson of the Senate Committee on Foreign Relations¹⁸.

In 2016, President Barack Obama exercised this authority to waive restrictions under the AECA’76 and Section 40 of the ECRA’18, enabling the provision of defense articles and services to vetted Syrian opposition groups. 

Under the FAA’61, the president may waive certain aid restrictions to a designated foreign government if they determine that doing so is justified by national security interests or humanitarian reasons. The president must consult with the relevant congressional committees 15 days in advance and submit a report to the Speaker of the House and the Chairperson of the Senate Committee on Foreign Relations outlining the reasons for the waiver.¹⁹

Congress can also bypass existing restrictions on foreign aid to a designated government by including waiver language in annual appropriations bills—typically authorizing assistance “notwithstanding any other provision of law.” 

For example, in the Comprehensive Peace in Sudan Act of 2004 (Public Law 108–497), Congress authorized the president to provide assistance to areas of Sudan—including Darfur and Southern Sudan—despite Sudan’s designation as an SST. The statute included a “notwithstanding any other provision of law” clause, which functioned as a legislative waiver mechanism.

This legislative strategy provides a parallel route to override SST-related constraints. Therefore, both the Executive and Legislative branches have the ability to exercise their own prerogative to overlook the provisions laid out by the ECRA’18, the FAA’61 and the AECA’76.

Lessons from the Recent History of Removing Designations 

Over the years, the US Secretary of State and the president have exercised their authority to remove six foreign governments from the SST list. These cases underscore a core principle: delisting hinges not on regime rhetoric but on concrete shifts in behavior that align with US interests. In past cases—Libya, Sudan, Iraq—the US responded to measurable actions: cutting ties with armed groups, resolving legacy terrorism cases, and repositioning diplomatically. 

Syria’s Interim Government (IG) under Ahmad al-Sharaa has already begun to chart this course. His administration has dissolved Hay’at Tahrir al-Sham, the former militia-cum-political party of victorious rebels that ousted Bashar al-Assad and which Sharaa once led. It has also launched operations against remnant Hezbollah networks supporting regime insurgents or attempting to continue to smuggle weapons from Iran into Lebanon. The IG has also intensified efforts to combat captagon production and trafficking and has stepped up its campaign against Islamic State remnants and sleeper cells. These actions suggest a strategy partly aimed at satisfying key US security concerns. 

The US initially handed Syria a list of conditions that it wanted Damascus to fulfill in exchange for partial sanctions relief. While the Trump administration has now announced that it will “cessate” sanctions without clarifying how this political announcement relates to these conditions, the latter remain useful benchmarks for any eventual removal of the SST designation. These include: 

• making sure foreign fighters are not installed in senior roles in Syria’s governing structure
• deporting Palestinian militants and making sure that armed factions outside state control will not be permitted
• helping prevent an ISIS resurgence
• barring an Iranian military presence
• removing foreign fighters and designated terrorists from the ranks of the Syrian army. 

Despite Trump’s announcement, these objectives remain core US priorities and are likely to shape any future delisting process. 

Iraq

These conditions echo past precedents. The US first added Iraq to the SST list on 29 December 1979 under Saddam Hussein’s regime, citing its support for proscribed militant groups such as the Palestinian Liberation Front, the Abu Nidal Organization, and Mojahedin-e-Khalq. In 1982, the US removed Iraq from the list to allow American aid during the Iran–Iraq War.

At the time, the EAA’79 required the Secretaries of Commerce and State to notify the House Foreign Affairs Committee and the Senate Committee on Banking, Housing and Urban Affairs 30 days before issuing any export license for Iraq. However, the EAA’79 did not outline a formal delisting process. It was reported that “apparently without consulting Congress, the [Ronald Reagan] Administration [had] quietly dropped Iraq, a virulent foe of Israel, from a list of countries barred from receiving American weapons because they have repeatedly supported acts of international terrorism.” 

The US re-designated Iraq in 1990 after it invaded Kuwait, and removed it again in 2004, citing a fundamental shift in the Iraqi government’s leadership and policies, the cessation of support for terrorism, and assurances by Iraq’s interim government that it would not sponsor terrorism in the future. 

South Yemen

The US also added South Yemen to the SST list on 29 December 1979 due to its support for several left-wing terrorist groups. It was removed in 1990 when it ceased to exist as a sovereign state after merging with North Yemen.

Libya 

Libya under Muammar Gaddafi joined the SST list on the same date—29 December 1979—for its support of leftist militant groups. The US began engaging Libya in 1999, prompting Libyan efforts to address terrorism concerns, including the transfer of suspects in the Pan Am 103 bombing. By 2001, the US and UK held direct negotiations with Libya. On 15 August 2003, Libya sent a letter to the UN Security Council pledging to renounce terrorism and cooperate in the global fight against it.

Libya accepted responsibility for the actions of its officials in the Pan Am 103 incident, agreed to pay over USD 2 billion in compensation to victims’ families, and promised full cooperation with investigations. In December 2003, Libya announced it would abandon its weapons of mass destruction (WMD) and missile delivery programs. President George W. Bush welcomed the decision and pledged to reciprocate Libya’s policy shift. Following continued cooperation, on 15 May 2006, the US announced that Libya would be removed from the list after a 45-day wait period, with the president submitting a report on Libya to Congress on 15 May 2006. According to a note by the US State Department, “Libya is an important model to point to as we press for changes in policy by other countries (such as Iran, North Korea, and others), changes that are vital to US national security interests and to international peace and security.” 

Congress did not invoke the blocking procedure available under the AECA’76. Following the delisting, however, the Senate adopted Senate Resolution 504 (Lautenberg), and Representative Mike Ferguson introduced House Resolution 838 in the House—though it was not considered²⁰—urging the president to require clear assurances from Libya before accepting its diplomatic credentials. These assurances included resolving outstanding claims from US victims of Libyan-sponsored terrorism and ensuring continued cooperation on cases like Pan Am 103 and the La Belle Discotheque bombing.

North Korea

The US designated North Korea as an SST in 1988 following the 1987 bombing of Korean Air Flight 858. It removed the designation on 26 June 2008 after North Korea issued a 60-page declaration detailing its nuclear program, meeting a major US demand. 

Prior to the delisting, Senator Sam Brownback introduced Senate Resolution 399 to establish benchmarks for North Korea, including issues related to weapons proliferation, terrorism, counterfeiting, narcotics trafficking, abductions, and unresolved POW matters from the Korean War. While the Senate did not act on the resolution, Representatives Ileana Ros-Lehtinen and Brad Sherman introduced similar measures in the House—neither of which advanced. 

The Trump administration re-designated North Korea in 2017.

Cuba

The US added Cuba to the list on 1 March 1982, citing Havana’s active support for revolutionary movements in Latin America and Africa. The US accused Cuba of providing training, arms, safe havens, and advice to guerrilla groups. 

On 30 May 2015, the US removed Cuba from the list after a comprehensive review led by President Obama’s Secretary of State John Kerry. Congress did not block the delisting, although H.Res. 181 (King) had called for the extradition of more than 70 US fugitives believed to be in Cuba. 

The Trump administration re-designated Cuba in 2021.

Sudan

President Bill Clinton’s administration designated Sudan as an SST in 1993, alleging that it harbored members of the Abu Nidal Organization, Hezbollah, and the PIJ. In the late 2000s, US and Sudanese officials engaged in negotiations on civil conflict, human rights abuses, and international terrorism. 

In January 2017, President Obama issued an order to review US–Sudan relations. This followed Sudan’s pledge to maintain a cessation of hostilities, improve humanitarian access, and cooperate on regional conflicts and terrorism. The review marked a step toward lifting sanctions and ending the national emergency. 

In November 2018, the first Trump Administration signaled that it would consider delisting Sudan if it met conditions related to human rights and religious freedom. On 14 December 2020, Trump’s Secretary of State Mike Pompeo formally removed Sudan from the SST list. 

Conclusion 

Syria’s continued presence on the SST list reflects a designation rooted in past behaviors and a regime that no longer defines the country’s present reality. With the collapse of the Assad regime and the emergence of new leadership that has distanced itself from key regional actors such as Hezbollah, the time has come for Washington to reassess whether this designation continues to serve US strategic and security interests. In light of President Trump’s recent announcement on the cessation of sanctions, removing Syria from the SST list should be a low-hanging fruit—one that would carry significant reputational benefits for international actors seeking to engage with the transitional government and could create space for more effective engagement on counterterrorism and reconstruction. Keeping Syria on the SST list without a clear, updated justification risks turning what was meant to be a calibrated policy tool into a static relic of a bygone era.


References:
1: Section 40A of the Arms Export Control Act of 1976 (AECA’76) states that the president must determine and certify to Congress, by 15 May of the calendar year in which that fiscal year begins, that a country is not cooperating fully with United States antiterrorism efforts.
2: Public disclosure is not mandated by the Act itself. However, these designations often become public through public notices published by the State Department.
3: “State” and “government” are used interchangeably in the text.
4: The designation on countries not fully cooperating with US counterterrorism efforts is technically called a “certification.”
5: Section 1754(c) of the Export Control Reform Act of 2018 (ECRA’18; Title XVII, Subtitle B, Part I, of the John S. McCain National Defense Authorization Act for Fiscal Year 2019; PL 115–232; 50 USC 4813).
6: Requires a 30-day Congressional notification for goods or services that could significantly enhance the terrorist-list country’s military capability or ability to support terrorism.
7: Section 1754(c) of the ECRA’18.
8: The Bureau of Industry and Security is responsible for advancing US national security, foreign policy, and economic objectives by ensuring an effective export control and treaty compliance system and promoting continued US strategic technology leadership.
9: The FAA’61 requires the president to consult with the Committees on Foreign Affairs (House) and Foreign Relations (Senate) 15 days in advance of any such waiver; and to submit a detailed report on the national security interests or humanitarian reasons that require such a waiver to the Speaker of the House and Chairperson of the Senate Committee on Foreign Relations.
10: Section 40(A)(d) of the AECA’76 states that “No defense article or defense service may be sold or licensed for export under this Act in a fiscal year to a foreign country that the president determines and certifies to Congress, by May 15 of the calendar year in which that fiscal year begins, is not cooperating fully with United States antiterrorism efforts.”
11: Under the International Emergency Economic Powers Act, which is the key enforcement tool to implement and punish violations of the economic sanctions that follow such designations, “a person who willfully commits, willfully attempts to commit, willfully conspires to commit, or aids or abets in the commission of a violation of any license, order, regulation, or prohibition may, upon conviction, be fined not more than $1,000,000, or if a natural person, be imprisoned for not more than 20 years, or both.”
12: Federal, State, and/or Local jurisdictions.
13: According to Section 1621 of the International Financial Institutions Act (22 USC 262p–4q), “The Secretary of the Treasury shall instruct the United States executive director of each international financial institution to use the voice and vote of the United States to oppose any loan or other use of funds” for countries that the Secretary of State has determined are state sponsors of terrorism.
14: As of April 2025, the US holds significant voting power across the World Bank Group institutions, with 15.83 % at the International Bank for Reconstruction and Development; 17.11% at the International Finance Corporation, and 9.67% at the International Development Association.
15: Funds that the Bank passes on to a third-party recipient; the Bank plays an operational role, such as appraising and supervising funded activities.
16: Section 40(d) of the AECA’76.
17: Section 1754(c) of the ECRA’18.
18: Section 40(g) of the AECA’76.
19: Section 620A(d) of the FAA’61.
20: The House resolution was introduced but never debated or voted on.