USA – WASHINGTON, DC Trends and Developments Contributed by: Jonathan M. Epstein, Daniel E. Goren, Tahlia Townsend and Manny Levitt, Holland & Knight LLP
wide, making it more essential than ever to monitor developments, assess the degree to which opera - tions present sanctions risks, and address such risks through appropriate policies and procedures. In cases of apparent violation, OFAC strongly encourages par - ties to investigate and disclose the issues to OFAC, and offers reductions from the maximum applicable penalty for timely, well-organised and thorough volun - tary disclosures with robust remedial measures. Key Trends and Developments in 2025 Donald Trump’s return to the Presidency in Janu - ary 2025 and resulting leadership changes at OFAC, State, DOJ, the Department of Commerce (“Com - merce”) and other foreign policy positions have led to significant shifts in the US government’s sanc - tions policy and enforcement priorities. However, in several material respects, the Trump Administration has continued or intensified sanctions approaches that emerged in previous administrations. Thus far, US sanctions policy in 2025 appears to be primarily driven by the following geopolitical issues: • the fall of the regime of Bashar Al-Assad in Syria; • activities by cartels and drug traffickers in Mexico, Latin America, and the Caribbean; • Iran and Iran-affiliated parties’ support for terrorist organisations and destabilising activities, procure - ment of ballistic weapons and crewless aerial vehi - cles (UAVs), and pursuit of nuclear weapons; • the Russian Federation’s ongoing attack on Ukraine and the efforts to negotiate a ceasefire; and • the 7 October 2023 terrorist attacks on Israel by Hamas, and Israel’s military response in Gaza. A review of sanctions designations, enforcement actions, and guidance issued by the White House, OFAC, the DOJ, and other agencies in 2025 clarifies the key targets, trends, and enforcement priorities that have emerged for the Trump Administration. We dis - cuss these and other relevant developments below. Syria: A Preliminary Reprieve from the US Embargo On 23 May 2025, following the fall of the Bashar al- Assad regime in December 2024 and the new Syr - ian government’s outreach, OFAC, State, and the
Financial Crimes Enforcement Network (FinCEN) took actions to provide preliminary relief from the US embargo on Syria. Relief was granted initially through the issuance of General License 25 (“GL 25”), which authorised a broad range of activities involving Syria that would otherwise be prohibited under the Syria Sanctions Regulations (“SSR”). State also issued a 180-day waiver of the sanctions mandated by Section 7432 (b)(1) of the Caesar Syria Civilian Protection Act of 2019 (“Caesar Act”), which accounts for certain blocked Syrian parties and certain investment restrictions, and FinCEN issued an excep - tion under the USA Patriot Act, allowing US finan - cial institutions to open and maintain correspondent accounts for the Commercial Bank of Syria. On June 30, 2025, President Trump issued an Execu - tive Order terminating the US government’s Syria sanc - tions program and directing other actions to revoke the vast majority of US trade restrictions imposed on Syria by the US government. In announcing the recission, OFAC stated that “[t]he circumstances that gave rise to OFAC’s Syria sanctions program, related to the brutal former regime of Bashar al-Assad, have been transformed by developments over the past six months, including the positive actions taken by the new Syrian government under President Ahmed al-Sharaa.” Notably, following the recission and in accordance with a review ordered by President Trump, State revoked the FTO designation of Hay’at Tahrir al-Sham (HTS), the group closely associated with the new government of Syria. Despite these actions, significant restrictions remain in effect as of August 2025, including comprehen - sive US export controls and prohibitions on transac - tions involving any individuals and entities associ - ated with the former regime of Bashar al-Assad and other “destabilizing actors in the region” linked to ISIS and al-Qaida affiliates, as well as Iran and its prox - ies, who remain subject to blocking sanctions. Relief from the (limited) Caesar Act restrictions also cannot be extended beyond 180 days without congressional action. Designating Mexican, Latin American, and Caribbean Cartels and Other Narcotics Traffickers
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