**Report on Council Decision CFSP 2025/1096 Amending Decision 2013/255/CFSP Concerning Restrictive Measures in View of the Situation in Syria**
**1. Executive Summary:**
This report analyzes Council Decision CFSP 2025/1096, which amends Decision 2013/255/CFSP concerning restrictive measures in view of the situation in Syria. The amendment aims to ease economic sanctions following the fall of the al-Assad regime while maintaining restrictions on individuals and entities linked to the regime, the chemical weapons sector, and illicit drug trade. Key changes involve lifting sectoral restrictions, extending the overall application of the decision, and modifying provisions related to entry bans, asset freezes, and exceptions for humanitarian aid and reconstruction efforts. This report details these changes, identifies the stakeholders, and infers the expected outcomes.
**2. Introduction:**
This report provides an informative analysis of Council Decision CFSP 2025/1096 based solely on the provided text. The purpose is to outline the specific amendments made to Decision 2013/255/CFSP concerning restrictive measures in view of the situation in Syria and to assess the potential implications of these changes.
**3. Policy Overview:**
* **Original Policy:** Council Decision 2013/255/CFSP concerning restrictive measures in view of the situation in Syria.
* **Core Objective(s):** Based on the text, the overarching objective of the initial policy was to impose restrictive measures in response to the situation in Syria. The amendment retains restrictions based on security concerns, while intending to support the Syrian people in reuniting and rebuilding a new, inclusive, pluralistic and peaceful Syria free from harmful foreign interference by lifting economic sanctions.
**4. Background and Rationale:**
The provided text suggests that the reason for this specific amendment is to adapt the EU's restrictive measures following the fall of the al-Assad regime in Syria. While the EU seeks to support reconstruction and engagement with Syria, it also acknowledges ongoing instability and the risk of resurgence of the former regime's influence. The amendments are designed to lift broad economic sanctions to aid the Syrian people while maintaining targeted restrictions against individuals and entities associated with the former regime, chemical weapons proliferation, and the illicit drug trade, particularly focusing on those who pose a threat to a peaceful transition.
**5. Key Provisions / Changes:**
The amendment introduces several key changes to Decision 2013/255/CFSP. These include:
* **Lifting of Sectoral Restrictions (Recital 7):** All sectoral restrictive measures are lifted, except for those based on security grounds. This constitutes a significant easing of economic sanctions.
* **Extension of Application (Article 34):** The decision's period of application is extended until 1 June 2026.
* **Amendment of Article 27 (Entry Restrictions):** Expands on the description of those subject to entry bans, specifying leading businesspersons linked to the former al-Assad regime, members of the al-Assad or Makhlouf families, Syrian Government Ministers and high-ranking military/security officials in post between May 2011 and December 2024, members of pro-Assad militias, and persons operating in the chemical weapons proliferation sector.
* **Amendment of Article 28 (Asset Freezes):** Similar to Article 27, the amendment expands on the description of those subject to asset freezes, mirroring the categories listed for entry restrictions. Specific exemptions regarding the use of frozen funds for basic needs of listed individuals and for payments by Syrian State-owned entities to the OPCW are retained, with some modifications to the wording.
* **Amendment of Article 28a (Humanitarian Exemptions):** Modifies exemptions to the prohibition on making funds available to listed entities. Exemptions for humanitarian relief and assistance to the civilian population, including the purchase and transport of petroleum products, are maintained. Derogations are added allowing Member States to authorise the release of funds for cooperation between listed entities and a Member State's governmental body in areas such as reconstruction, counterterrorism and migration, under specific conditions.
* **Deletion of Articles and Annexes (Article 1):** Articles 5, 6, 7, 7a, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26 and 28b are deleted, alongside Annexes II and III.
* **Addition to Article 34 (Maritime Zones):** Any violation of the sovereign rights of Member States within their maritime zones shall immediately trigger a discussion for the amendment of restrictive measures, in the context of the constant review of the restrictive measures.
The effect of these changes is a relaxation of broad economic sanctions, coupled with a refinement and extension of targeted sanctions against individuals and entities deemed to pose a threat to the stability and peaceful transition of Syria.
**6. Target Audience and Stakeholders:**
Based on the text, the following are directly affected:
* **Syrian People:** The easing of economic sanctions is intended to support the Syrian population.
* **Individuals and Entities Listed in Annex I:** These individuals and entities remain subject to entry bans and asset freezes.
* **Leading Businesspersons Operating in Syria Linked to the Former al-Assad Regime:** These individuals are specifically targeted by the amended restrictions.
* **Members of the al-Assad and Makhlouf Families:** Targeted by the restrictive measures.
* **Syrian Government Ministers, Military and Security Officials in Power under the al-Assad Regime:** Subject to the restrictive measures.
* **Member States:** Responsible for implementing the restrictive measures and potentially authorizing exceptions for humanitarian aid and reconstruction efforts.
* **Entities involved in reconstruction, counterterrorism and migration initiatives:** These may be able to cooperate with governmental bodies under exemptions to the asset freeze.
* **The Syrian Arab Republic:** Regarding payments to the OPCW for chemical weapons destruction.
**7. Implementation Aspects (Inferred):**
* **Responsible agency/bodies:** Member States are responsible for implementing the entry bans and asset freezes. The Council of the European Union is responsible for amending Annex I (the list of sanctioned individuals and entities). Competent authorities of Member States may authorize the release of certain funds for humanitarian or reconstruction cooperation.
* **Timelines or procedures:** The decision applies until 1 June 2026. The exceptions outlined in Article 28a will be reviewed at regular intervals, and at least every 12 months. The Council must act upon a proposal by a Member State or the High Representative of the Union for Foreign Affairs and Security Policy to amend the list in Annex I. A request for information or a notification for additional time from the relevant competent authority within five working days of the date of receipt of a request for authorisation under paragraph 7 should be considered granted.
**8. Expected Outcomes / Impact of Changes:**
The likely intended outcomes of these specific changes are:
* **Economic Relief for the Syrian Population:** The lifting of broad economic sanctions is expected to alleviate some of the economic hardship faced by the Syrian people.
* **Continued Pressure on the Former al-Assad Regime:** The targeted sanctions are intended to prevent the resurgence of the former regime's influence and hold accountable those responsible for repression and human rights abuses.
* **Facilitation of Humanitarian Aid and Reconstruction:** The amendments seek to facilitate the provision of humanitarian aid and support reconstruction efforts while preventing funds from falling into the hands of sanctioned individuals and entities.
* **Maintaining the integrity of maritime zones.** The inclusion of Article 34 on maritime zones indicates an attempt to prevent the violation of the sovereign rights of Member States within their maritime zones.
**9. Conclusion:**
Council Decision CFSP 2025/1096 represents a significant adjustment to the EU's policy towards Syria. The decision attempts to balance the need to provide economic relief to the Syrian population with the imperative of maintaining pressure on the former al-Assad regime and preventing further instability. The changes highlight the EU's commitment to a peaceful transition in Syria, while also signaling a willingness to adapt its approach based on the evolving situation on the ground. The modifications to provisions regarding entry bans, asset freezes, and humanitarian exceptions are crucial for understanding the practical implications of the amended policy. These changes represent a refinement of existing restrictive measures, aiming to target sanctions more effectively and allow for greater flexibility in providing humanitarian aid and reconstruction assistance.
Key Entities Referenced
European Union: A political and economic union of member states located primarily in Europe.
Official Journal: The official gazette of the European Union.
Council Decision CFSP 2025/1096: Council Decision concerning restrictive measures in view of the situation in Syria
27 May 2025: Date of the Council Decision CFSP 2025/1096.
Decision 2013/255/CFSP: Council Decision concerning restrictive measures in view of the situation in Syria, which is being amended.
Syria: A country in the Middle East, subject to restrictive measures according to the policy document.
Treaty on European Union: The foundational treaty of the European Union.
Article 29: Article of the Treaty on European Union, regarding the Common Foreign and Security Policy.
High Representative of the Union for Foreign Affairs and Security Policy: The EU's chief diplomat, responsible for the Common Foreign and Security Policy.
31 May 2013: Date when Council Decision 2013/255/CFSP was adopted.
Decision CFSP 2024/1510: Council Decision extending restrictive measures set out in Decision 2013/255/CFSP until 1 June 2025.
27 May 2024: Date of the Council Decision CFSP 2024/1510.
1 June 2025: The date until which the restrictive measures set out in Decision 2013/255/CFSP were extended.
al-Assad regime: The former ruling government in Syria.
24 February 2025: Date when the Council eased a number of Union restrictive measures in view of the situation in Syria.
European Council: A collective of heads of state or government of the EU member states that provides political direction.
20 March 2025: Date when the European Council underlined the importance of a peaceful and inclusive transition in Syria.
20 May 2025: Date when the Council announced its political decision to lift its economic sanctions on Syria.
Syrian people: Citizens of Syria.
1 June 2026: The date until which the restrictive measures set out in Decision 2013/255/CFSP are extended.
Member States: The countries that are part of the European Union.
Annex I: An annex to the decision, listing persons and entities subject to restrictive measures.
Council Decision CFSP 2015/1836: Council Decision amending Decision 2013/255/CFSP concerning restrictive measures against Syria.
12 October 2015: Date of Council Decision CFSP 2015/1836.
Syrian Armed Forces: The military forces of Syria.
May 2011: Starting date of the period of government ministers and members of the Syrian Armed forces and the Syrian security and intelligence services that are subject to restrictive measures
December 2024: Ending date of the period of government ministers and members of the Syrian Armed forces and the Syrian security and intelligence services that are subject to restrictive measures
al-Assad or Makhlouf families: Families associated with the al-Assad regime.
11 March 2025: Date of the High Representative of the Union for Foreign Affairs and Security Policy statement
Union: Referring to the European Union.
OPCW: Organisation for the Prohibition of Chemical Weapons.
Syrian Arab Republic: Another name for Syria.
Syrian State: Referring to the government or state-owned entities of Syria.
Annex II: An annex to the decision, that is being deleted.
Annex III: An annex to the decision, that is being deleted.
Brussels: The city where the decision was made.
A. SZAPKA: The President of the Council.
19 December 2024: Date of the conclusions of the European Council
Syrian Special Trust Fund: Funds related to the complete destruction of Syrian chemical weapons outside the territory of the Syrian Arab Republic.
Official Journal EN
of the European Union L series
2025/1096 28.5.2025
COUNCIL DECISION (CFSP) 2025/1096
of 27 May 2025
amending Decision 2013/255/CFSP concerning restrictive measures in view of the situation in Syria
THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on European Union, and in particular Article 29 thereof,
Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy,
Whereas:
(1) On 31 May 2013, the Council adopted Decision 2013/255/CFSP(1).
(2) On 27 May 2024, the Council adopted Decision (CFSP) 2024/1510(2)extending the restrictive measures set out in
Decision 2013/255/CFSP until 1 June 2025.
(3) Following the fall of al-Assad’s regime in Syria, on 24 February 2025, the Council eased a number of Union
restrictive measures in view of the situation in Syria in order to facilitate engagement with the country, its people
and businesses in the areas of energy, transport and reconstruction, as well as to facilitate the associated financial and
banking transactions.
(4) On the same day, the Council issued a declaration stating that listings related to the al-Assad regime, the chemical
weapons sector and illicit drug trade should be maintained. The Council also declared that it will continue to
examine whether the suspensions remain appropriate, based on the close monitoring of the situation in the country,
and it will consider the steps taken by Syria for an inclusive transition in line with the declarations of the transitional
authorities, including accountability for the al-Assad regime’s crimes, respect for human rights and fundamental
freedoms of all Syrians without distinction of any kind, and rule of law and international law. The Council called for
an end to interference in the country of destabilising foreign actors, recalling the respect for sovereignty, territorial
integrity and unity of Syria.
(5) On 20 March 2025, the European Council underlined the importance of a peaceful and inclusive transition in Syria,
free from harmful foreign interference, and the protection of the rights of Syrians from all ethnic and religious
backgrounds without discrimination. The European Council also highlighted that comprehensive transitional justice
in particular is essential on the path to reconciliation. The European Council outlined the Union’s suspension of
restrictive measures as part of a gradual, reversible approach on the basis of close monitoring of the situation in
Syria.
(6) On 20 May 2025, the Council announced its political decision to lift its economic sanctions on Syria, to support the
Syrian people in reuniting and rebuilding a new, inclusive, pluralistic and peaceful Syria free from harmful foreign
interference.
(7) On this basis, the Council considers that all sectoral restrictive measures should be lifted, with the exception of those
based on security grounds.
(1) Council Decision 2013/255/CFSP of 31 May 2013 concerning restrictive measures in view of the situation in Syria (OJ L 147,
1.6.2013, p. 14, ELI: http://data.europa.eu/eli/dec/2013/255/oj).
(2) Council Decision (CFSP) 2024/1510 of 27 May 2024 amending Decision 2013/255/CFSP concerning restrictive measures in view of
the situation in Syria (OJ L, 2024/1510, 28.5.2024, ELI: http://data.europa.eu/eli/dec/2024/1510/oj).
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OJ L, 28.5.2025
(8) Despite the fall of the al-Assad regime and the establishment of the transitional authorities, the situation in Syria
remains unstable and al-Assad’s network, spread inside and outside Syria, has not yet been held accountable and
cannot be considered dissolved. There remains a credible risk of destabilisation and a potential resurgence of the
former regime’s influence, exemplified by the incidents in support of the al-Assad regime aimed at undermining the
transitional process, that have led to deadly violence in Syria’s coastal region. Listed individuals and entities linked to
the al-Assad regime continue to hold powerful influential roles and pose a risk of supporting, through financing or
other means, further armed conflict, and may play a part in attempts to reverse the transition. In her statement of
11 March 2025 on behalf of the Union, the High Representative of the Union for Foreign Affairs and Security Policy
expressed grave concerns about the widespread violence in Syria’s coastal region and strongly condemned the
attacks by pro-Assad militias against security forces and the horrific crimes committed against civilians, including
summary killings, and stressed in this regard that effective measures must be taken to prevent such crimes from
happening again.
(9) Members of the al-Assad and Makhlouf families and associated individuals have yet to be held accountable for their
involvement in the brutal repression against the civilian population in Syria and pose a risk of trying to escalate
conflict and hinder the peaceful transition in Syria.
(10) Syrian Government Ministers in power after May 2011 under the former al-Assad regime are to be considered
jointly and severally responsible for the policy of repression pursued by the former al-Assad regime and continue to
pose a risk to the peaceful transition in Syria.
(11) Militias, armed groups, security forces and intelligence bodies connected to the former al-Assad regime and loyal to
the former regime pose a risk of further escalation and repression against the civilian population in Syria.
(12) More than 100 suspected chemical weapons sites remain in Syria after the fall of the al-Assad regime, a number
much higher than ever acknowledged before the fall of the al-Assad regime. The destruction of Syria’s remaining
chemical weapons stockpiles remains a priority to ensure the protection of the Syrian population, as outlined in the
conclusions of the European Council of 19 December 2024.
(13) Leading businesspersons operating in Syria linked to the al-Assad regime and who have amassed substantial wealth
and power due to this connection remain influential and their networks have stayed in place. As such, these
individuals carry an inherent risk of violent repression of the civil society and the peaceful transition in Syria.
(14) On the basis of a review of Decision 2013/255/CFSP, the restrictive measures set out therein should be extended
until 1 June 2026.
(15) Decision 2013/255/CFSP should therefore be amended accordingly,
HAS ADOPTED THIS DECISION:
Article 1
Decision 2013/255/CFSP is amended as follows:
(1) in Article 27, paragraphs 1 and 2 are replaced by the following:
‘1. Member States shall take the necessary measures to prevent the entry into, or transit through, their territories of
the persons responsible for the violent repression against the civilian population in Syria, persons benefiting from or
supporting the former al-Assad regime, and persons associated with them, as listed in Annex I.
2. In accordance with the assessments and determinations made by the Council in the context of the situation in
Syria as set out in recitals 5 to 12 of Council Decision (CFSP) 2015/1836(*) and recitals 8 to 13 of Council
Decision (CFSP) 2025/1096(**), Member States shall also take the necessary measures to prevent the entry into, or
transit through, their territories of:
(a) leading businesspersons operating in Syria linked to the former al-Assad regime;
(b) members of the al-Assad or Makhlouf families;
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OJ L, 28.5.2025
(c) Syrian Government Ministers in power between May 2011 and December 2024;
(d) members of the Syrian Armed Forces of the rank of “colonel” and the equivalent or higher in post between May
2011 and December 2024;
(e) members of the Syrian security and intelligence services in post between May 2011 and December 2024;
(f) members of al-Assad regime-affiliated militias; or
(g) persons operating in the chemical weapons proliferation sector,
and persons associated with them, as listed in Annex I.
(*) Council Decision (CFSP) 2015/1836 of 12 October 2015 amending Decision 2013/255/CFSP concerning
restrictive measures against Syria (OJ L 266, 13.10.2015, p. 75, ELI: http://data.europa.eu/eli/dec/2015/1836/
oj).
(**) Council Decision (CFSP) 2025/1096 of 27 May 2025 amending Decision 2013/255/CFSP concerning restrictive
measures in view of the situation in Syria (OJ L, 2025/1096, 28.5.2025, ELI: http://data.europa.eu/eli/dec/2025/
1096/oj).’;
(2) Article 28 is amended as follows:
(a) paragraphs 1 and 2 are replaced by the following:
‘1. All funds and economic resources belonging to, or owned, held or controlled by persons responsible for the
violent repression against the civilian population in Syria, persons and entities benefiting from or supporting the
former al-Assad regime, and persons and entities associated with them, as listed in Annex I, shall be frozen.
2. In accordance with the assessments and determinations made by the Council in the context of the situation
in Syria as set out in recitals 5 to 12 of Council Decision (CFSP) 2015/1836 and recitals 8 to 13 of Decision (CFSP)
2025/1096, all funds and economic resources belonging to, or owned, held or controlled by:
(a) leading businesspersons operating in Syria linked to the former al-Assad regime;
(b) members of the al-Assad or Makhlouf families;
(c) Syrian Government Ministers in power between May 2011 and December 2024;
(d) members of the Syrian Armed Forces of the rank of “colonel” and the equivalent or higher in post between
May 2011 and December 2024;
(e) members of the Syrian security and intelligence services in post between May 2011 and December 2024;
(f) members of al-Assad regime-affiliated militias; or
(g) members of entities, units, agencies, bodies or institutions operating in the chemical weapons proliferation
sector,
and persons and entities associated with them, as listed in Annex I, shall be frozen.’;
(b) paragraph 5 is replaced by the following:
‘5. No funds or economic resources shall be made available, directly or indirectly, to or for the benefit of, the
natural or legal persons or entities listed in Annex I.’;
(c) paragraph 6, point (a) is replaced by the following:
‘(a) necessary to satisfy the basic needs of the persons listed in Annex I and their dependent family members,
including payments for foodstuffs, rent or mortgage, medicines and medical treatment, taxes, insurance
premiums, and public utility charges;’;
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OJ L, 28.5.2025
(d) paragraph 6, point (h) is replaced by the following:
‘(h) intended for the Syrian State-owned entities, as listed in Annex I, to make payments on behalf of the Syrian
Arab Republic to the OPCW for activities related to the OPCW verification mission and the destruction of
Syrian chemical weapons, and in particular to the OPCW Syrian Special Trust Fund for activities related to the
complete destruction of Syrian chemical weapons outside the territory of the Syrian Arab Republic.’;
(e) paragraph 7, point (a) is replaced by the following:
‘(a) the funds or economic resources are subject of an arbitral decision rendered prior to the date on which the
person or entity referred to in paragraph 1 or 2 was listed in Annex I or of a judicial or administrative decision
rendered in the Union, or a judicial decision enforceable in the Member State concerned, prior to or after that
date;’;
(f) paragraph 7, point (c) is replaced by the following:
‘(c) the decision is not for the benefit of a person or entity listed in Annex I; and’;
(g) paragraph 9 is deleted;
(h) paragraph 13 is replaced by the following:
‘13. Paragraphs 1, 2 and 5 shall not apply to a transfer, by or through a financial entity listed in Annex I, of
frozen funds or economic resources where the transfer is related to a payment by a person or entity not listed in
Annex I in connection with the provision of financial support to Syrian nationals pursuing an education,
professional training or engaged in academic research in the Union, provided that the relevant Member State has
determined, on a case-by-case basis, that the payment is not directly or indirectly received by a person or entity
referred to in paragraph 1 or 2.’;
(i) paragraph 15 is deleted;
(j) paragraph 16 is deleted;
(3) Article 28a is amended as follows:
(a) paragraph 2 is replaced by the following:
‘2. The prohibition set out in Article 28(5) shall not apply to funds or economic resources made available to the
natural or legal persons and entities listed in Annex I by public bodies, or by legal persons or entities which receive
public funding to provide humanitarian relief in Syria or to provide assistance to the civilian population in Syria,
where the provision of such funds or economic resources is for the purchase or transport of petroleum products,
or associated financing or financial assistance, for the sole purposes of providing humanitarian relief in Syria or to
provide assistance to the civilian population in Syria.’;
(b) paragraph 5 is replaced by the following:
‘5. The prohibition set out in Article 28(5) shall not apply to funds or economic resources made available to the
natural or legal persons or entities listed in Annex I by diplomatic or consular missions.’;
(c) the following paragraphs are added:
‘7. By way of derogation from Article 28(1), (2) and (5), the competent authorities of a Member State may
authorise the release of certain frozen funds or economic resources, or the making available of certain funds or
economic resources, to entities listed as Number 42 and Number 43 in “Section B. Entities” in Annex I, under such
conditions as they deem appropriate, after having determined that the provision of such funds or economic
resources is necessary for the cooperation between those entities and a Member State’s governmental entity or
body in the areas of reconstruction, capacity-building, counter-terrorism and migration.
8. In the absence of a negative decision, a request for information or a notification for additional time from the
relevant competent authority within five working days of the date of receipt of a request for authorisation under
paragraph 7, that authorisation shall be considered granted.
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OJ L, 28.5.2025
9. The Member State concerned shall inform the other Member States and the Commission of any
authorisations granted under paragraph 7 within four weeks of such authorisation.’;
(4) Article 29 is replaced by the following:
‘Article 29
No claims, including for compensation or indemnification or any other such claim, such as a claim of set-off, fines or
a claim under a guarantee, claims for extension or payment of a bond, financial guarantee, including claims arising
from letters of credit and similar instruments in connection with any contract or transaction the performance of which
was affected, directly or indirectly, wholly or in part, by reason of measures covered by this Decision, shall be granted
to the designated persons or entities listed in Annex I, or any other person or entity in Syria, including the
Government of Syria, its public bodies, corporations and agencies, or any person or entity claiming through or for the
benefit of any such person or entity.’;
(5) in Article 30, paragraph 1 is replaced by the following:
‘1. The Council, acting upon a proposal by a Member State or the High Representative of the Union for Foreign
Affairs and Security Policy, shall establish and amend the list in Annex I.’;
(6) Article 31 is replaced by the following:
‘Article 31
1. Annex I shall include the grounds for listing the persons and entities concerned.
2. Annex I shall also contain, where available, the information necessary to identify the persons or entities
concerned. With regard to persons, such information may include names, including aliases, date and place of birth,
nationality, passport and identity card numbers, gender, address if known, and function or profession. With regard to
entities, such information may include names, place and date of registration, registration number and place of
business.’;
(7) Article 34 is replaced by the following:
‘Article 34
1. This Decision shall apply until 1 June 2026. It shall be kept under constant review. It may be renewed, or
amended as appropriate, if the Council deems that its objectives have not been met. The exceptions referred to in
Article 28a(1) to (4) as regards Article 28(1), (2) and (5) shall be reviewed at regular intervals, and at least every 12
months, or at the urgent request of any Member State, the High Representative or the Commission following
a fundamental change in circumstances.
2. The Council underlines the importance of preventing the violation of the sovereign rights of Member States
within their maritime zones in accordance with the law of the sea. At the request of a Member State, any such
violation shall immediately trigger a discussion for the amendment of restrictive measures, in the context of the
constant review of the restrictive measures.’;
(8) Articles 5, 6, 7, 7a, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26 and 28b are deleted;
(9) Annex II is deleted;
(10) Annex III is deleted.
Article 2
This Decision shall enter into force on the day following that of its publication in the Official Journal of the European Union.
Done at Brussels, 27 May 2025.
For the Council
The President
A. SZŁAPKA
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