Following the overthrow of the Assad regime on 8 December 2024, the debate on Syria’s transition and rebuilding efforts has largely focused on the lifting of Western sanctions imposed against Syria since the popular uprising and insurgency began in 2011. Sanctioning states, including members of the European Union (EU), the United Kingdom (UK), and the United States (US), have responded to regime change in Damascus, first timidly and then more decisively, by lifting most of their sectoral, trade, and financial sanctions, statedly to give the new Syria a chance to get back on its feet.
Much less attention has been given to the designation of hundreds of regime-affiliated individuals, companies, and other entities who since 2011 have been subjected to sanctions, including asset freezes, exclusion from trade and transactions, and travel bans. The reasons why these individuals and entities were sanctioned vary, but are all related to the Assad regime’s brutal repression and the responsibility its incumbents and accomplices carry for war crimes and crimes against humanity.
Such individual designations seem to have been primarily informed by expectations that sanctions would put pressure on the Assad regime to stop the mass violence it unleashed on its own population and induce it to allow for a democratic transition, or simply to signal disapproval of the regime’s refusal to do either. Yet with the fall of the regime, targeted sanctions have transformed into tools of accountability for the regime’s crimes. This report explores the synergy between individual designations or targeted sanctions, the need for transitional justice and accountability in post-Assad Syria, and steps taken in this regard by the transitional government led by Hayat Tahrir al-Sham (HTS) and by sanctioning states.
Unlike most trade and financial sanctions against Syria, many individual designations have been kept in place. A large majority of these sanctions involve former incumbents of the Assad regime, officials who held positions of political power, senior military officers, members of the regime’s notorious intelligence agencies (mukhabarat), business elites affiliated with the regime, drug traffickers linked to the regime, and those who led an array of paramilitary forces or militias on which the regime relied to fight a vicious insurgency. In their review of sanctions against Syria, sanctioning states have made it clear that they do not intend to remove most individual designations. Some restrictive measures have been initiated against some new individuals and entities, mostly in response to the large-scale outbreak of sectarian violence in Syria’s coastal region in March 2025. Yet the Syria sanctions regimes of the EU, UK, and US have primarily become a tool to enforce accountability for the Assad regime’s past crimes.
The need for a sanctions-based strategy serving and complementing Syria’s own transitional justice efforts are apparent. Many former incumbents and supporters of the Assad regime have moved abroad, placed and hidden their assets outside Syria, and/or continue to rely on international partners and enablers to escape justice. International sanctions can limit their room to maneuver and degrade their assets. Judicial capacities within Syria fall dramatically short of effectively prosecuting war criminals and violators of human rights; targeted sanctions can help to reinforce these capabilities, complement them, and temporarily substitute for them.
Yet the question of how individual designations are to be integrated into Syria’s transitional justice efforts, and how this can serve accountability, still needs to be answered, and urgently so. Designated individuals and entities associated with the Assad regime have gone to great lengths to avoid the impact of sanctions, principally by moving to jurisdictions that ignore sanctions imposed by Western states and that show little regard for the accountability concerns motivating them. Furthermore, Syria’s interim authorities must somehow strike a balance between responding to the wide demand for accountability, on the one hand, and the imperatives of preserving “civil peace” and promoting economic recovery, on the other. Sanctions can play a positive role in—but can also complicate—where this balance is struck and, as importantly, how it is struck and by whom. For sanctions to serve accountability, they need to be carefully and comprehensively targeted at the Assad regime’s most notorious violators of human rights. This also implies a case-by-case reassessment of the listing of individuals who were included in earlier designations.
For individual designations to be effective, merely listing war criminals and their accomplices is insufficient. Efforts should be made to more tightly integrate the designation of individuals and entities into sanctioning states’ foreign policies, diplomacy, provision of aid, and judicial endeavors. To effectively and credibly serve accountability for Syria, sanctioning states must also themselves uphold transparency and accountability in their designations. Finally, preparations should be made to go beyond sanctions and disentangle the complexities associated with seizing assets of sanctioned individuals and entities and making these available to victims of the Assad regime. This report does not explore asset seizures and restitution as such, but it may serve as useful background if and when such efforts will be made in the future.
This report documents and analyzes how since 8 December 2024 sanctioning states, Syria’s transitional government, and Syrian civil society have responded to challenges related to transitional justice and accountability through effectively designating and sanctioning those responsible for war crimes and crimes against humanity under the Assad regime. We acknowledge that these challenges have been enormous and that it may still be too early to draw final conclusions.
Imperatives of justice, accountability, and effective sanctioning had to compete with other priorities, including instantaneous conflict management within the highly polarized society left behind by the Assad regime. The interim authorities faced and still face enormous tasks, including rebuilding state institutions, catering for immediate socio-economic needs, and grappling with aggressive policies taken by Syria’s neighbors, including Israel. Yet we observe an alarming tendency for both the meaningful pursuit of transitional justice and the effective alignment of individual designations with accountability for past regime crimes to take a back seat to other considerations—or be overruled by them. Syria’s interim authorities have thus far failed to get the balance right between justice and more pragmatic considerations of preserving stability and recovery. As damagingly, the ways in which the transitional government has tried to strike this balance failed to be transparent and inclusive. As a result, it risks losing the very window of opportunity presented by the Assad regime’s fall, while victims may feel let down or even encouraged to take matters into their own hands.
Sanctioning states as well have failed thus far to take the robust measures needed to ensure that sanctions are targeted, effectively implemented, and reinforced by other means. They also do not meet the standards of accountability that their own sanctions are supposed to serve. Finally, Syria’s transitional government and the sanctioning states have yet to initiate an effective dialogue about how their policies and priorities are to align and complement each other, thereby causing a real risk that their approaches will contradict or clash with each other.
The report takes a close look at the hundreds of designated individuals and entities that have been kept under Western sanctions since the fall of the Assad regime. We provisionally distinguish between “henchmen,” “business elites,” and “bureaucrats” to illustrate how senior regime incumbents (the Assad family, its closest aides, military figures, and mukhabarat chiefs), businessmen (“cronies” and “frontmen”), and state officials reinforced and were responsible for repressive, authoritarian rule drenched in mass violence and a denial of basic human rights. The report then presents an assessment of the whereabouts of designated individuals, their assets, and the status of still enlisted entities—primarily sanctioned companies—in the post-Assad era.
We then document and analyze the policies and steps taken by the Syrian transitional government relevant to transitional justice, discuss its vision in this respect, and provide an overview of the criticisms it faced in pursuing accountability generally and vis-à-vis members of the Assad regime more specifically. We then unpack the transitional government’s approach to the business elites associated with the former regime, its motivations for striking deals with some of them, and the seizure of some of their assets and restructuring of their companies. The report then focuses on the lists of designated individuals and companies, how they can be improved to better serve accountability for the crimes of the Assad regime, how imposing sanctions can be made more transparent and accountable, and ways in which enforcing existing designations can be made more effective, including by integrating targeted sanctions tightly into sanctioning states’ foreign policies, diplomacy, aid provision, and judicial approaches.
This report will focus on the targeted sanctions imposed by the EU, UK, and US only. Other sanctioning states’ designations and policies toward Syria, such as those of Switzerland, Australia, and Canada, are not discussed. However, these states’ designations show a strong overlap with those of the EU, UK, and US, so our findings are relevant to them as well. We also do not explicitly focus on the individual designations imposed by the UN Security Council on individuals and entities relevant to the situation in Syria. UN-sanctioned individuals and entities almost exclusively comprise those suspected of Jihadist and other “terrorist” activities in Syria.[1] Sharp disagreements within the UN Security Council over the situation in Syria allowed consensus only on sanctioning these individuals and entities, not those accused of human rights abuses associated with the Assad regime.
While the report focuses on accountability issues associated with sanctioned members of the Assad regime and its accomplices, genuine transitional justice in the real world cannot and should not be this selective. Most Syrians realize this, as shown by an opinion survey held in August–July 2025 wherein 65 percent of respondents were of the view that “[a]nyone who took part in war crimes, whether members of the former regime or the opposition” should be held accountable.[2] Indeed, for an effective and credible strategy toward transitional justice, all perpetrators of gross human rights violations and mass violence during the Syrian conflict should be included. Thus far the Syrian transitional government has failed this test, as it has explicitly reserved its vision for transitional justice to perpetrators of the Assad regime and thereby leaving the door open to impunity for others equally responsible for war crimes and crimes against humanity, including members of HTS and other armed groups allied with the current government.
In our research for this report we faced serious obstacles in obtaining reliable, clear, complete, and verified data. The very difficulty of fully overcoming these obstacles speaks volumes about what is wrong with Syria’s post-Assad path toward transitional justice, while also underscoring the lack of transparency in a sanctions regime that claims to pursue accountability for others.
The Assad regime surely played its part in hiding responsibility for its crimes and obscuring the corruption, collusion, and extortion in how it managed the economy. Access to documents prepared by Syria’s numerous mukhabarat agencies often revealed as much about the Assad regime’s crimes as it did about the smoke and mirrors of regime officials—the backstabbing and intrigues in which facts were easily sacrificed for personal gain and survival. After Assad’s fall, many members of his regime and its business allies who fled Syria tried to erase their tracks and hide their assets while shielding themselves behind the state sovereignty of host countries who are unlikely to prosecute or extradite them. Yet the Syrian transitional government’s own lack of transparency and its secrecy when dealing with issues of accountability and transitional justice—especially involving business elites and their companies—equally posed a serious challenge to our efforts to gather data and documentation.
Against this complex background, unsubstantiated rumors and inaccurate reporting circulated, often making it hard to distinguish fact from fiction. We found that the murky and erratic deal-making between the transitional government and Assad regime perpetrators, including businessmen, created an atmosphere where potential informants—such as accountants who served the regime’s business elites—were reluctant to come forward with evidence. They could not be sure they would not face repercussions jeopardizing their personal safety, either through reprisals from the new government or from their former regime-linked bosses who had been or could yet be rehabilitated.
Stories based on mistaken identity added to the mix of misinformation, such as when Jamal Younes, a senior commander of the Fourth Division notorious for mass atrocities and subjected to sanctions, seemingly appeared in a video taken at Hmeimim airport in March 2025, shouting pro-Assad slogans and demanding international protection. Yet after the video had gone viral on social media, the same man appeared in a second video denying he was Jamal Younes.[3] More often than not, reported arrests of former regime incumbents turned out to be a hoax, such as the alleged capture in January 2025 of Ghassan Jawdat Ismail, the sanctioned chief of the infamous Air Force Intelligence Directorate (AFID).[4]
In short, for a highly contentious topic like the one of this report, and explored under rather tumultuous conditions, one can expect the threshold of proof to be set at a high level, but realistically so. Understandably, most interviewees we consulted for this report asked for their names to be withheld. In other instances, we can only describe the nature and contents of some incriminating documents, because releasing them would likely put those who provided us with these documents in danger. Throughout the report and its appendices, we indicated clearly at what level of confidence we assess the accuracy of the information that we present.
We sent a draft version of this report to the Syrian interim government and the sanctioning states. The British Foreign, Commonwealth and Development Office (FCDO) discussed the report with us in an online meeting. The US Department of State said it did not have any further questions or comments. The Syrian interim government and the office of the EU’s High Representative of Foreign Affairs and Security Policy did not reply.
This report draws on a wide range of sources. Publicly accessible online sources, including social media, were indispensable, primarily to prompt and direct our investigations. A small team of Open-Source Intelligence (OSINT) researchers at the Observatory of Political and Economic Networks (OPEN) collected and analyzed a mass of data in this manner, which has been especially useful in tracing the whereabouts of former regime incumbents and business elites and to establish the status of sanctioned companies. The OSINT team included Mahmoud Alaashiq, Joanne Chlela, and Ahmad Dandashi.
For data on business elites, their companies, networks, and links to regime incumbents during the Assad years, we relied on OPEN’s database that maps tens of thousands of verified relationships among many Syrian and non-Syrian actors, including registered businesses, members of Parliament, heads of security branches, religious leaders, warlords, civil society organizations, UN agencies, business elites, militia leaders, and senior Syrian army officers. Where relevant, we also consulted OPEN’s database on Lebanon. The databases are compiled from a range of data sources, including the Syrian and Lebanese Official Gazettes (Al-Jarida Al-Rasmiyya), official government announcements, the Damascus Stock Exchange, open-source news articles, and other sources such as the UN Procurement Database, video documentaries, and obituaries.[5] The databases include all individuals and entities sanctioned by the EU, UK, and US. Wael Alalwani provided technical support in using the OPEN database.
Perhaps most instructively, we conducted many interviews in Syria, primarily but not only in Damascus, during several visits: in December 2024 and in May–June, July, and October 2025. In December 2024, and in July and October 2025, our investigations brought us briefly to Beirut.[6] The report also draws on some interviews held earlier, before the fall of the regime. These interviews were conducted clandestinely by research assistants within Syria. Our interviewees comprised businessmen, transitional government officials, middlemen, former militiamen, journalists, human rights activists, lawyers, and former regime officials. In addition, about a dozen interviews were held online, primarily with officials of the two sanctioning states and the EU, Syrian human rights activists and researchers, Syrian businessmen residing outside Syria, and international lawyers.
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References
[1] “United Nations Security Council Consolidated List,” accessed 1 November 2025.
[2] “Arab Opinion Index: Syrian Public Opinion Survey 2025,” Arab Center Washington DC, 18 September 2025.
[3] The Syrian Revolution 2011, “After a video circulated from inside the Russian Hmeimim Base...” (in Arabic), Facebook, 12 March 2025; Journalist Waheed Yazbek, “We told you it was not Major General Jamal Younes…” (in Arabic), Facebook, 13 March 2025.
[4] Samir Ahmad Nuhaili, “Arrest of General Ghassan Ismail…” (in Arabic), Facebook post, 27 January 2025.
[5] The Syrian Official Gazette was accessed at https://odd.syria-report.com.
[6] The German Gerda Henkel Foundation helped finance Dr. Leenders’ visit to Damascus in May–June 2025 as part of its support for a research project he leads on paramilitary groups in Syria, Iraq, and Afghanistan. It also funded interviews conducted by research assistants before the fall of the regime.