How OFAC Sanctions Affect Syrian Crypto Users in 2025

In mid‑2025 the United States dramatically rewrote the rules that had kept Syrian cryptocurrency users at arm’s length for more than two decades. The shift went from a blanket ban to a narrowly targeted regime, opening the door for ordinary Syrians to trade on global platforms while still keeping a tight leash on regime‑linked actors. If you’re a Syrian crypto enthusiast, a compliance officer, or just curious about how sanctions shape digital finance, this guide tells you exactly what changed, why it matters, and what you need to do next.

TL;DR - Quick Takeaways

• Executive Order 14312 (June302025) revoked the six core Syrian sanctions executive orders, effective July12025.
• OFAC removed the Syrian Sanctions Regulations (SySR) on August262025, erasing the blanket crypto ban.
• General License25 now authorizes Syrian users to transact with U.S. crypto services, provided they are not on the targeted SDN list.
• Over 500 individuals and entities were delisted, expanding the pool of eligible crypto participants.
• Compliance teams must adopt sophisticated screening to avoid serving the remaining 100‑plus sanctioned Assad‑linked actors.

Background: The pre‑2025 OFAC sanctions regime

Since the early 2000s, the Office of Foreign Assets Control (the Treasury bureau that administers and enforces U.S. economic sanctions) has overseen a web of prohibitions aimed at Syria. The core legal framework-known as the Syrian Sanctions Regulations (a set of rules codified in 31C.F.R. Part569 that barred most financial activity involving Syrian persons)-was built on six executive orders dating back to 2004 (E.O.13338, 13399, 13460, 13572, 13573, 13582). Under this regime, any crypto transaction that involved a Syrian individual, a Syrian‑registered exchange, or a U.S.‑based wallet provider was automatically illegal, exposing violators to civil penalties up to $20million or twice the transaction value.

These prohibitions forced Syrian users to rely on offshore mixers, peer‑to‑peer networks, or completely off‑grid solutions, dramatically limiting their ability to access mainstream crypto markets.

2025 Sanctions Relief - What actually changed?

The turning point arrived on June302025 when President Trump signed Executive Order14312 (titled “Providing for the Revocation of Syria Sanctions” and aimed at dismantling the pre‑existing Syria‑related sanctions framework). The order revoked the six earlier executive orders and terminated the underlying national emergency, making the change effective on July12025.

Implementation followed a two‑step process:

1. On August262025, OFAC published a final rule that completely removed the Syrian Sanctions Regulations from the Code of Federal Regulations.
2. On September242025, the agency renamed the program to Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations (PAARSS) (a rebranded, targeted‑sanctions regime focusing on regime actors rather than the Syrian populace).

In parallel, the General Licenses24 and25 (authorizations issued by OFAC that permit certain otherwise prohibited activities) remained in force. General License25, issued on May282025, explicitly grants blanket permission for crypto transactions that would have been blocked under the old SySR, provided the counterparties are not on the SDN list.

What General License25 actually allows

For a Syrian crypto user, General License25 translates into a legal pathway to:

• Open accounts on U.S.‑based exchanges (e.g., Coinbase, Binance.US) without fear of immediate civil or criminal penalties.
• Use U.S. wallet providers that hold custodial or non‑custodial services.
• Participate in DeFi protocols that are hosted on U.S. infrastructure, as long as the protocol’s smart contracts are not owned by sanctioned entities.
• Import mining hardware and blockchain infrastructure under the new BIS “License ExceptionSyria Peace and Prosperity (SPP)” (see next section).

However, the license does not waive the targeted sanctions that remain on more than 100 individuals and entities linked to the Assad regime, human rights abusers, Captagon traffickers, or ISIS/Al‑Qa’ida affiliates. Crypto platforms must therefore screen every counterparty against the Specially Designated Nationals and Blocked Persons List (SDN List) (OFAC’s master list of entities subject to U.S. sanctions).

Remaining targeted sanctions - compliance headaches

Even after the blanket ban was lifted, the U.S. kept a laser‑focused set of sanctions:

• Assad‑regime officials and family members.
• Companies involved in the production or distribution of Captagon.
• Entities tied to Syria’s past weapons‑of‑mass‑destruction proliferation.
• Iranian proxies operating in Syria.

For crypto service providers, this means building a compliance stack that can:

1. Run real‑time SDN checks on onboarding and on‑chain activity.
2. Implement risk‑scoring models to flag transactions that involve high‑risk addresses (e.g., wallets linked to sanctioned exchanges).
3. Maintain audit trails that demonstrate due diligence, satisfying both OFAC and FinCEN guidance (FinCEN’s June42025 memo still applies).

Practical impact on Syrian crypto users

Below are the concrete changes you’ll notice on the ground:

• Exchange access: Syrian residents can now pass KYC checks on mainstream U.S. platforms, provided they submit valid identity documents and are not listed on the SDN.
• Wallet services: Custodial wallets (e.g., Crypto.com) now openly support Syrian phone numbers, while non‑custodial wallets benefit from reduced fear of seizure.
• Mining equipment: The BIS License ExceptionSyria Peace and Prosperity (SPP) (a new export‑control exception that authorizes the shipment of EAR99 items, including ASIC miners, to Syria) removed the need for individual export licenses, letting local entrepreneurs import modern rigs.
• DeFi participation: With fewer legal obstacles, Syrian users can now provide liquidity on Uniswap‑type platforms without fearing that their tokens will be frozen by U.S. authorities.
• Remittance & peer‑to‑peer payments: Services like RippleNet or stable‑coin transfers are now permissible, expanding cross‑border payment options.

That said, the delisting of 518 individuals and entities from the SDN List means a sudden influx of new users. Platforms that previously blocked any Syrian IP address may need to recalibrate their geo‑blocking rules.

Compliance checklist for crypto platforms serving Syrian users

To stay on the right side of the law, providers should adopt the following steps:

1. Update onboarding screens: Replace “Syria‑blocked” dropdowns with a “Syrian resident - please provide national ID” field.
2. Integrate real‑time OFAC screening: Use APIs that pull the daily SDN List and flag any wallet address or entity name that matches.
3. Conduct enhanced due diligence (EDD) on high‑risk users: If a user’s name appears in any of the 100+ remaining target lists, run manual reviews and potentially reject the account.
4. Maintain transaction monitoring thresholds: Set higher scrutiny for large (>$10,000) crypto‑to‑fiat conversions involving Syrian bank details.
5. Document compliance decisions: Keep logs of why a Syrian user was approved or denied, referencing the specific General License or OFAC guidance.
6. Train staff on PAARSS updates: Ensure compliance teams are aware of the new program name and its focus on targeted individuals.

Future outlook: What’s next for Syrian crypto regulation?

OFAC has signaled that PAARSS will evolve. Expected developments include:

• Additional interpretive guidance clarifying which crypto‑related activities fall under the “targeted sanctions” umbrella.
• Possible expansion of General License24 to cover emerging blockchain‑based identity solutions.
• Further export‑control relaxations that could allow Syrian startups to import AI‑enhanced mining software.

For users, the trend points toward greater financial inclusion, but for platforms, the compliance burden will stay high as the U.S. refines its targeted‑sanctions approach.

Before vs. After: Quick comparison

Key takeaways for everyday users

If you’re a Syrian resident looking to get back into crypto, here’s a simple 3‑step plan:

1. Verify you’re not on the SDN List (use the publicly available OFAC search tool).
2. Choose a U.S. exchange that supports Syrian KYC (e.g., Kraken, Coinbase) and complete the identity verification.
3. Keep transaction amounts reasonable and retain records; if asked, cite General License25 as your legal basis.

Remember, OFAC sanctions still apply to the targeted individuals, so staying clear of any flagged names is vital.