Hana Attia, Leuphana University & German Institute for Global and Area Studies
Introduction
Economic sanctions have evolved into the go-to response to challenges of international peace and security. Since the 1990s, the US, EU, and UN have imposed more than 400 sanctions to address a wide range of issues, including armed conflict, human rights violations, drug trafficking, terrorism, and nuclear proliferation (Attia and Grauvogel 2022). Yet sanctions regimes are often criticized for exhibiting lock-in effects, whereby the political and institutional mechanisms that facilitate their imposition simultaneously constrain their removal. Prominent examples include Cuba, Iran, Sudan, Zimbabwe, and Iraq, all of which have been subject to sanctions for decades and shaped debates on sanctions termination. The difficulty of terminating sanctions even after their original goals have been overtaken by events represents a significant obstacle to achieving durable change.
The recent experience of Syria offers an empirical case to reassess termination processes. On May 13, 2025, six months after the fall of the Assad regime, President Donald Trump announced the cessation of US sanctions against Syria (Reuters 2025). The US decision followed similar moves by the EU and UK, which had effectively removed most sanctions against Syria by that time. Originally imposed in 2011 against the Assad regime, these Western sanctions targeted specific individuals and entities and extended to Syria’s key industries, including energy, finance, and transport. Over time, the measures were expanded to target any state or entity supporting the Syrian government, its military, or reconstruction efforts (Caesar Syria Civilian Protection Act of 2019). The sanctions weakened the state’s capacity in an attempt to pressure the government for change, while inflicting significant humanitarian harm on the broader population (Human Rights Watch 2023) and affecting daily life for many Syrians.[1] The rapid termination of the Syrian sanctions regime after the fall of Assad has been described as a rare instance of swift and accelerated policy reversal in the Middle East and reportedly caught Trump’s own administration off guard, leaving sanctions officials scrambling to determine how to unwind the measures (The Straits Times 2025).
The Syrian case challenges two common assumptions in IR research on sanctions: first, that (longstanding) sanctions invariably create lock-in effects for policymakers; and second, that sanctions termination is synonymous with sanctions relief – namely, with economic relief. Using Syria as a primary case, this research note examines the dynamics of sanctions-termination processes showing how political pragmatism facilitated the lifting of sanctions in the case of Syria. At the same time, it underscores the persistent challenges of translating political decisions into tangible economic recovery. By connecting Syria with other examples, the essay argues that sanctions termination is neither a linear nor a binary process, but rather a prolonged and “volatile” one (Grauvogel and Attia 2019). Even after sanctions removal, lingering uncertainty among Western governments and continued investor caution have delayed economic normalization, creating openings for emerging actors – particularly the Gulf states and Turkey – to reshape post-sanctions engagement.
In sum, the Syrian case challenges scholarly work that emphasizes the lock-in effects of sanctions by showing that political will among sanctioning states can overcome barriers to sanctions termination, while also demonstrating that sanctions relief does not automatically lead to effective post-sanctions recovery, revealing the need to pay greater attention to the afterlife of sanctions.
The (prolonged) process of terminating sanctions
Scholarship on sanctions has overwhelmingly focused on sanctions imposition and effectiveness, while the termination of these measures has received comparatively little attention. Existing approaches often treat sanctions as static events, overlooking the ways in which both their imposition and termination unfold over time. This tendency is particularly evident in large-N studies that typically code sanctions termination as a singular endpoint, thereby lumping all termination processes together and assuming that sanctions are imposed and lifted in a uniform, all-at-once manner (but see Attia et al. 2020; Krustev and Morgan 2011). This gap is noteworthy given that more than one-third of the sanctions imposed between 1990 and 2018 have been lifted gradually rather than in a single step (Attia and Grauvogel 2022).
Recent large-N studies have started to address the first limitation by distinguishing between different types of sanctions termination, separating cases in which termination follows target compliance from those in which termination results from sender capitulation, i.e. when senders lift sanctions despite incomplete goal attainment (Attia et al. 2020; Jeong 2019; Krustev and Morgan 2011). This research shows that these two termination pathways are not mirror images of one another and are instead driven by distinct factors. Large-N studies remain constrained by data limitations when assessing how sanctions end, since most sanctions datasets provide only a single termination date for each sanctions case or episode (Attia and Grauvogel 2022; Morgan et al. 2014; Weber and Schneider 2022). As a result, they insufficiently capture prolonged termination processes in which specific measures are gradually lifted over time. Meanwhile, qualitative case studies highlight the evolutionary nature of sanctions, but still largely focus on their imposition rather than termination (Eriksson 2007).
Existing research on sanctions termination highlights that lifting sanctions is often more difficult than imposing them. The decision to lift sanctions often concerns stigmatized and ostracized regimes (Hellquist 2018). Sanctions label targets as “pariah states” (Early and Jadoon 2016) and facilitate the adoption of hostile policies against them (Peterson and Drury 2011). Ending sanctions against such states is not merely a matter of removing economic restrictions; it also involves the act of diplomatically reintegrating the target into the international community (Grauvogel and Attia 2019). Given that the decision concerns states and actors labeled as pariahs or major violators, scholars argue that it is easier for the senders to get into than out of sanctions. Moreover, particularly in longstanding sanctions cases, sanctions tend to create “lock-in” effects (Attia et al. 2020). Years of political justification and institutional investment in maintaining a sanctions regime (Bonetti 1994) make it harder to reverse the policy. As a consequence, policymakers often struggle to end sanctions once the time comes to do so (Biersteker, Eckart, and Tourinho 2016).
The case of Syria
Syria presents a major recent case of sanctions imposition and termination. Syria has been under sanctions since 1979, when the US first designated it as a state sponsor of terrorism (SST). Over the years, it was targeted by several additional rounds of sanctions, codified through executive decisions and legislation. This continued until 2011, when the US and EU imposed sweeping measures against the Assad regime, targeting specific individuals and entities, and extending restrictions to the country’s key industries, including energy, finance, and transport. The most devastating were the US sanctions under the Caesar Syria Civilian Protection Act of 2019, which were extraterritorial in nature.
After the fall of the Assad regime in December 2024, Western governments moved swiftly to lift sanctions against Syria. Despite the speed of these developments, there was a significant lag between the fall of Assad and the political imperative to lift sanctions and the actual termination of all sanctions. I divide the termination process in the period from December 2025 to January 2026 into four phases, highlighting key decisions as measures were gradually removed: the first phase starts after the fall of Assad, when the US issued the time-bound General License 24 on January 6, 2025, which allowed transactions with the new governing institutions to provide essential services, including electricity and energy, and to ease hardship while broader sanctions remained in place. The EU and UK also began lifting or suspending sanctions, with the UK moving ahead more aggressively by unfreezing assets, delisting banks, and easing restrictions across several sectors by the end of February. By the end of April, the UK had revoked most sectoral and financial sanctions on the country.
The second phase began on May 13, when President Trump announced the cessation of US sanctions against Syria. The US Department of the Treasury followed by issuing a new General License 25, which effectively lifted most Syria-related sanctions and included a 180-day waiver of the Ceasar Act pending repeal by Congress. Similarly, on May 20, the EU announced the lifting of all remaining economic sanctions against Syria. One month later, a US executive order formally revoked sanctions and ended the national emergency concerning Syria. Targeted sanctions against al-Assad and his affiliates over human rights violations remained.
The third phase began on July 8, when the US not only lifted Syria-specific sanctions but also revoked the Foreign Terrorist designation of HTS. This move allows financial transactions with the transitional government under current President Ahmed al-Sharaa, the head of HTS,[2] and facilitates broader re-engagement with Syria. On November 6, the United Nations Security Council removed the designations of Syria’s President al-Sharaa and Interior Minister Anas Khattab under the sanctions regime targeting members and supporters of terrorist groups ISIL and al-Qaeda. The fourth phase began on December 19, when President Trump signed into law the formal repeal of the Caesar Act, which was considered the major hurdle to reinvestment in Syria.
Rapid sanctions relief
The case of Syria challenges prevailing assumptions about the durability and lock-in effects of longstanding sanctions and offers an example of an accelerated policy reversal in the Middle East. While leadership change is often associated with sanctions relief, the Syrian case is puzzling because the new governing authorities are themselves deeply stigmatized actors and also targeted by sanctions for well over a decade. Thus, sanctions related stigmatization and ostracization discussed in the literature operated on two levels: first, through the targeting of Syria, and second, through the designation of HTS as a Foreign Terrorist Organization and its leaders as Specially Designated Global Terrorists. Yet, the Trump administration framed the lifting of measures as keeping designations and sanctions only on “the worst of the worst,” which includes members of the former Assad regime and now notably excludes former designated terrorists al-Sharaa and members of his transitional government (U.S. Department of State 2025). This swift shift in policy marked by the removal of sanctions has been described as “sudden” (The Straits Times 2025), “surprising” (Gillian and Lankes 2025), and – with respect to the removal of al-Sharaa and HTS designations – as an abrupt departure in US policy (Ungar 2025) and a rapid and “dramatic” shift in European, especially German, policy.[3] Despite the speed of this policy shift, it generated notable domestic contestation in the US, highlighting the political barriers to lifting sanctions. Around 134 Republican House members threatened to reimpose sanctions (U.S. Congress 2025), Senator Lindsey Graham vowed to “push for reimposing […] sanctions on steroids” if the transitional government attacks Kurdish forces (U.S. Senator Lindsey Graham 2026), and some Democrats in Congress stressed that sanctions relief is not “unconditional” (Welat TV 2026).
This rapid removal of sanctions was driven by political pragmatism of the sanctioners that wanted to gain influence over Syria’s political transition. Their objectives were threefold: first, limiting the influence of rivals in the emerging contest to redraw the country’s geopolitical map following an era marked by Iranian dominance and Russian influence; second, advancing counterterrorism goals by preventing Syria from becoming a ground for renewed jihadi or proxy-conflict activity (Alterman 2025); and third, striving to shape Syria as a stable pillar in the region, perceiving it as a key component of the transforming architecture of the Middle East (Wieland 2025). This was evident in US efforts to press Syria into a security agreement with Israel, in a US attempt to secure its key ally in the region. For the EU – especially Germany and Italy, who were the vocal proponents of a quick lifting of sanctions – in addition to security concerns, a stable and safe Syria is key to refugee return (European Council of the European Union 2025; European Council on Refugees and Exiles 2025). It was also facilitated, albeit to a much lesser extent by civil society advocacy. Due to their scope, the sanctions against Syria inflicted significant harm on the broader population (Human Rights Watch 2023), contributing to a humanitarian emergency and harming the socio-economic well-being of ordinary citizens (Moret 2015). Thus, as soon as the Assad regime fell, civil society advocacy began to press for the removal of sanctions. More than 160 Syrian, as well as, international organizations, such as the Syrian Network for Human Rights, the American Coalition for Syria, and the Syrian Emergency Task Force, began calling for the EU and US to lift sanctions (Syrian British Consortium 2025; Syrian Network for Human Rights 2025). The civil society pressure even targeted individual legislators to push for the full repeal, and not only the suspension of sanctions to enable immediate reconstruction and recovery. Civil society pressure further underscored the geostrategic relevance of Syria for the West warning that a vacuum would risk heightened instability, potentially allowing Western adversaries such as Russia and Iran to “re-anchor” themselves (Eurobserver 2025). Yet translating these political decisions on sanctions relief into tangible economic recovery remained a challenge.
Sanctions lifted, uncertainty and economic constraints remain
The case of Syria illustrates that sanctions are not a simple switch that senders can turn on and off, and that the effects of sanctions measures persist even after they are formally lifted. Despite the removal of most EU and UK sanctions, European investors have continued to delay economic normalization. This hesitation stemmed largely from the different pace at which the various sanctioning states lifted “overlapping” sanctions (Maresca di Serracapriola and Shaar 2025). As outlined above, the EU and UK began easing sanctions prior to the US, with the UK moving particularly quickly by unfreezing assets and sectors. Yet, sanctions relief remained constrained by unresolved measures, especially the extraterritorial US sanctions. This lack of coordination also affected sanctions relief in other cases, such as Iran after the US withdrew from the Nuclear Deal, or the UN embargo against Iraq, where the different P5 members had strikingly different stances regarding the termination of the measures (Grauvogel and Attia 2023). Thus, coordination among senders is essential for reducing uncertainty about permissible economic activities and encouraging economic engagement with formerly sanctioned states.
Moreover, the first three phases of the termination process – which included the lifting of most US sanctions against Syria and members of the transitional government, and the formal suspension of the Caesar Act – is characterized by lingering uncertainty regarding economic engagement with Syria and slow economic normalization. The remaining sanctions measures, or the lifting of measures through suspension rather than repeal, created uncertainties for investors and complicate the work of humanitarian actors. For private actors, sanctions suspension or gradual termination creates regulatory uncertainty because they lack a clear understanding of what is allowed and what is not. Even if all activities and transactions are allowed, there is a lack of “trust” and foreign institutions remain “reluctant to reengage due to compliance risks and reputational concerns, while correspondent banking channels remain effectively frozen” (Fève et al. 2025, 5). Indeed many Western companies cited the suspension rather than the repeal of the Caesar Act as a key barrier to investing in the country, as it continues to hinder formal financial transfers and the establishment of correspondent banking relationships (Fève et al. 2025). Although the Caesar Act has now been formally repealed (phase four above), sanctions relief is likely to remain constrained by other measures, including the US designation of Syria as an SST and the continued listing of HTS under the UN ISIL and al-Qaeda sanctions regime. The SST designation subjects Syria to export controls, limiting “access to parts and machinery needed for reconstruction and development” (Maresca di Serracapriola and Hall 2025), whereas the HTS designation “sustains a high-risk compliance environment” increasing uncertainty over Syria’s reintegration into the global financial system (Maresca di Serracapriola and Hall 2026). Persisting security challenges and political instability, also add hesitation to engaging with the transitional government. These economic and security uncertainties have therefore created a context where sanctions termination cannot easily translate into economic relief. A similar dynamic was at play in the case of Iran, as many European companies judged the risk too high to engage with Iran despite sanctions termination granted under the Nuclear Deal (JCPOA).
In sum, the case of Syria demonstrates how sanctions termination does not automatically translate into economic relief from sanctions, due to the lingering effects of the measures that continue to dissuade private actors from engaging. The delayed economic normalization with the West has created openings for emerging actors – particularly the Gulf states and Turkey – allowing them to redefine post-sanctions engagement. This development was not as prominent in previous termination processes in the region, including Iran, Iraq, and Sudan, where regional actors did not play a significant role in shaping post-sanctions recovery. In the case of Syria, dozens of Memoranda of Understanding worth millions of dollars have already been signed between Syria and mainly Gulf and Turkish actors, signaling a prominent realignment in the Syrian investment landscape away from Russian and Iranian contracts (Karam Shaar Advisory 2025).
Conclusion
This essay examines the Syrian case, where the rapid termination of sanctions following the fall of Assad represents a rare instance of accelerated policy reversal in the Middle East, encouraging us to rethink sanctions termination processes. The case of Syria challenges two key assumptions: first, that longstanding sanctions ostracize targets and create a lock-in effect that makes their removal difficult, and second, that sanctions termination is synonymous with economic relief from sanctions. The analysis highlights how political pragmatism facilitated the lifting of sanctions. Western actors sought to, among other things, shape Syria as a stable pillar in the region, viewing it as a key component of the Middle East’s evolving geopolitical architecture, particularly following developments after October 7, 2023. Yet, while Western sanctioning states moved swiftly to lift sanctions on Syria following the fall of Assad, the essay demonstrates that sanctions relief does not automatically translate into effective economic recovery, revealing persistent structural barriers to post-sanctions reconstruction.
By connecting the Syrian case with other examples, the research note demonstrates that sanctions termination can be a prolonged process. It shows that even after the removal of the most restrictive sanctions, lingering uncertainty among Western governments and continued investor caution have delayed economic normalization, creating openings for emerging actors to redefine post-sanctions engagement. For Syria, economic recovery is essential for the country’s transition period. While the removal of sanctions is a positive step, it will not automatically translate into sanctions relief and economic recovery. Recovery will take time and must be facilitated by pro-active support from international actors, including the former sanctioning states. At the same time, the Syrian government must actively engage in economic reforms to address the country’s structural challenges and create the conditions for sustainable recovery.
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* The author is grateful to the participants of the Bologna Initiative for Sanctions Relief for their feedback on her intervention and for sharing their expertise at SAIS Bologna in November 2025, which motivated this essay. The author also thanks the participants of the POMEPS workshop for their constructive comments and Mailin Hüring for her excellent research assistance.
[1] This negative impact was further exacerbated by the Assad regime’s own mismanagement.
[2] During the Syrian Revolution Victory Conference in Damascus, on January 9, 2025, the spokesperson for the Military Operations Command, announced that HTS and several other armed groups were being dissolved and integrated into state institutions.
[3] Interview with Stefan Schneck Germany’s Special Envoy for Syria: https://karamshaar.com/syria-in-figures/interview-the-eus-position-toward-syria-step-by-step-not-step-for-step/.