Providing for the Revocation of Syria Sanctions

6/30/2025

Executive Orders

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Action Summary

Purpose & Background: Emphasizes U.S. support for a stable, unified, and peaceful Syria; acknowledges recent positive changes under President Ahmed al-Sharaa and initial steps taken via General License 25 and Caesar Act waivers.
Policy Shift: Transforms prior actions against the former Assad regime by removing sanctions on Syria, relaxing export controls, and enabling further actions by the State, Treasury, and Commerce departments while excluding relief for terrorist organizations and human rights violators.
Revocation of Syria Sanctions: Terminates the national emergency and revokes multiple Executive Orders (13338, 13399, 13460, 13572, 13573, 13582) effective July 1, 2025, while preserving actions or proceedings initiated before that date.
Accountability for the Former Regime: Expands sanctions under Executive Order 13894 (as amended) and related orders to target individuals and entities linked to war crimes, human rights abuses, chemical weapons use, and illicit activities during Bashar al-Assad’s regime.
Caesar Act Review: Directs the Secretary of State, in consultation with the Treasury, to assess whether criteria under the Caesar Act are met, with potential suspension or reimposition of related sanctions following congressional notification.
Syria Accountability Act Adjustments: Waives specific export control restrictions under the Act for items on the Commerce Control List, mandating a report to congressional committees.
CBW Act Waivers: Certifies changes in Syrian leadership and policies, thereby waiving sanctions related to foreign assistance, financial aid, export controls on sensitive items, and banking restrictions imposed due to prior chemical weapons use.
Counterterrorism Designations: Instructs actions to designate al-Nusrah Front (Hay’at Tahrir al-Sham) and Abu Muhammad al Jawlani as terrorists, while reviewing Syria’s status as a State Sponsor of Terrorism.
United Nations Engagement: Directs the Secretary of State to advance U.S. objectives at the UN, promoting a stable Syria, supporting anti-terrorism efforts, and exploring additional sanctions relief.
Implementation & General Provisions: Authorizes relevant executive departments to adopt necessary regulations and redelegate functions; underscores that the order does not confer enforceable individual rights, and mandates compliance with applicable law and appropriations.

Risks & Considerations

The revocation of sanctions on Syria could lead to increased geopolitical stability in the region, which may open up new opportunities for international collaboration and research for Vanderbilt University, particularly in areas related to Middle Eastern studies and international relations.
However, the removal of sanctions also poses risks if the situation in Syria deteriorates or if the new government fails to maintain peace and security. This could impact students and faculty involved in international programs or research in the region.
The focus on accountability for the former regime’s war crimes and human rights abuses may lead to increased scrutiny and potential legal challenges for individuals and organizations previously involved with the Syrian government. Vanderbilt University should ensure that its partnerships and collaborations are compliant with international laws and human rights standards.
The potential for increased economic activity in Syria following the lifting of sanctions could present opportunities for Vanderbilt’s business and economics programs to engage in research and partnerships focused on economic development and trade in the region.

Impacted Programs

Vanderbilt’s International Relations Program may see increased interest and opportunities for research and collaboration in Middle Eastern politics and diplomacy.
The Law School could engage in research and discussions on international law, human rights, and the implications of lifting sanctions on countries with complex political histories.
Peabody College might explore educational partnerships or exchange programs with institutions in Syria, contingent on the stability and security of the region.
The Office of Global Safety and Security should monitor the situation closely to ensure the safety of students and faculty involved in international programs related to Syria.

Financial Impact

The lifting of sanctions may lead to new funding opportunities for research and development projects focused on Syria and the broader Middle East, potentially benefiting Vanderbilt’s research initiatives.
There could be increased demand for expertise in international trade and economic development, providing opportunities for Vanderbilt’s business and economics programs to expand their offerings and partnerships.
Vanderbilt may need to allocate resources to ensure compliance with international laws and regulations, particularly in relation to partnerships and collaborations involving Syria.

Relevance Score: 3 (The order presents moderate risks typically involving compliance or ethics.)

Key Actions

Vanderbilt’s Office of Federal Relations should monitor the changes in U.S. foreign policy towards Syria, particularly the revocation of sanctions, to assess potential impacts on international collaborations and research opportunities. Engaging with federal agencies to understand the implications of these policy shifts could position Vanderbilt to capitalize on new opportunities for international partnerships.
The Department of Political Science should consider conducting research on the geopolitical implications of the U.S. policy changes towards Syria. This research could provide valuable insights into regional stability and inform policy recommendations, enhancing Vanderbilt’s role as a thought leader in international relations.
Vanderbilt’s Center for International Studies should explore opportunities to engage with Syrian academic institutions and scholars, leveraging the easing of sanctions to foster educational exchanges and collaborative research projects. This could enhance Vanderbilt’s global reach and contribute to rebuilding educational infrastructure in Syria.
The Peabody College of Education and Human Development could explore initiatives to support educational development in Syria, potentially through partnerships with international organizations focused on education in conflict zones. This aligns with Vanderbilt’s commitment to global education and development.

Opportunities

The revocation of sanctions presents an opportunity for Vanderbilt’s Owen Graduate School of Management to explore new markets and business opportunities in Syria. By understanding the evolving economic landscape, the school can develop programs and partnerships that prepare students for careers in international business and trade.
Vanderbilt’s Law School could offer courses or seminars on international law and sanctions, using the recent changes in U.S. policy towards Syria as a case study. This would provide students with practical insights into the complexities of international legal frameworks and their implications.
The focus on counterterrorism and regional stability offers an opportunity for Vanderbilt’s Institute for Global Health to engage in research and initiatives aimed at improving health outcomes in conflict-affected regions. Collaborating with international health organizations could enhance the institute’s impact and visibility.

Relevance Score: 3 (The executive order requires some adjustments to processes or procedures at Vanderbilt to align with new international opportunities and collaborations.)

Average Relevance Score: 3.8

Timeline for Implementation

Revocation of Syria Sanctions: Effective July 1, 2025.
CBW Act Waiver: Effective 20 days after the waiver determination is transmitted.
Caesar Act Briefing: The briefing must be provided within 30 days following the Secretary of State’s determination.

Determination: Among these timelines, the shortest period is the CBW Act waiver, which becomes effective in less than 30 days, indicating an urgent implementation schedule.

Relevance Score: 5

Impacted Government Organizations

Department of State: Charged with overall foreign policy implementation, sanction waivers, and representing U.S. interests at the United Nations.
Department of the Treasury: Responsible for managing financial sanctions, exemptions under export controls, and oversight of economic measures in Syria.
Department of Commerce: Involved in implementing export control relaxations and rule-making to support the waiver provisions outlined in the order.
Department of Transportation: Consulted in redelegation processes related to the order’s implementation measures.
Department of Justice (Attorney General): Tasked with taking appropriate counterterrorism actions and overseeing legal measures related to designated entities.
Office of Management and Budget (OMB): Referenced regarding its budgetary, administrative, and legislative proposal functions that are indirectly impacted by the order.

Relevance Score: 3 (A moderate number of key Federal Agencies are impacted by this executive action.)

Responsible Officials

Secretary of State – Charged with overall implementation of key directives such as issuing waivers, managing sanctions relief, advancing U.S. policy at the United Nations, and coordinating on counterterrorism designations.
Secretary of the Treasury – Tasked with working in consultation with the Secretary of State to examine criteria for waivers, manage financial restrictions and sanctions, and help implement additional measures.
Secretary of Commerce – Authorized to adopt necessary rules and regulations to implement export control relaxations and other aspects of this order.
Attorney General – Involved in the consultation process regarding the designation of terrorism-related entities.
Secretary of Transportation – Consulted as appropriate for redelegated functions related to the Syria Accountability Act.

Relevance Score: 5 (Directives directly affect Cabinet-level officials responsible for critical national security and foreign policy decisions.)