On July 8, 2026, the U.S. Department of State announced that it intends to rescind Syria's designation as a State Sponsor of Terrorism (SST) following a 45-day pre-notification period. The announcement noted that this change will facilitate international trade and investment, giving Syria a chance to rebuild following the December 2024 overthrow of Bashar Al-Assad's regime. 

Under federal law, State has authority to punish foreign nations that have "repeatedly provided support for acts of international terrorism" by formally designating those nations as SSTs.¹ These nations are treated as pariah states that are subject to sanctions including restrictions on U.S. foreign assistance, bans on defense exports and sales, prohibitions on economic aid, and other punitive restrictions. 

State's plan to remove Syria's designation is a significant development with few analogues in recent history. In the 40 years since the SST designation came into existence, only eight nations have been designated as SSTs. The four current SSTs – Syria, Iran, North Korea, and Cuba – were all first designated in the 1980s and have remained on the SST list ever since, with limited interruptions when SST sanctions were briefly lifted on North Korea and Cuba in the early 2000s. Other previous SSTs were Iraq, Libya, South Yemen, and Sudan, which have all been de-designated. In 2022, a resolution was also introduced to add Russia to the SST list following its invasion of Ukraine, but that resolution was not adopted.

The removal of Syria's SST designation has important ramifications for U.S. exporters and for U.S. victims of foreign torture and terrorism who may contemplate bringing civil claims against Syria for their harms.

Implications for Exporters

Current export controls on Syria arose both from its status as an SST and from statutory authorities such as the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 (SAA). As a result, the lifting of comprehensive sanctions on Syria in 2025 did not automatically trigger a significant relaxation of all applicable export controls. Syria's continuing SST status means that it has remained an E:1 (terrorist-supporting) country subject to anti-terrorism controls under the Export Administration Regulations (EAR). As an E:1 country, an export license is required for the export, re-export, or in-country transfer of all items on the Commerce Control List to Syria. In addition, whenever the Secretary of State determines that a proposed export or re-export could make a significant contribution to Syria's military potential or support acts of international terrorism, the determination triggers a 30-day congressional notification requirement.

In relation to the lifting of comprehensive sanctions on Syria, the Department of Commerce's Bureau of Industry and Security (BIS) issued new license exceptions and rolled out less restrictive license review policies for many items in September 2025. However, anti-terrorism restrictions and congressional notification requirements endured because underlying SST and SAA certification requirements had not been met. Thus, the announced removal of Syria's SST designation should significantly alter many restrictive export controls. 

Shortly after the 45-day SST notification clock expires, BIS should issue revisions to the EAR moving Syria out of the E:1 country group and lifting corresponding license requirements for items controlled solely for anti-terrorism reasons. Various additional export license exceptions should then become available. The applicable de minimis level² for foreign-produced items would also rise from 10 percent to 25 percent of the item's total value. Altogether, these changes could enable significant expansion of Syria-facing export activities. 

To permanently lift export controls imposed under the SAA, the president must be able to certify a number of factors, including receipt of assurances from Syria that it has ceased and will not undertake future development or deployment of ballistic missiles or chemical, biological, or nuclear weapons. Somewhat mirroring the changes to export controls for Iraq after its SST designation was lifted, short-term changes to corresponding Syria embargoes and congressional notification provisions in the EAR may be limited to revisions rather than full removal in the absence of a concurrent certification under the SAA. 

Exporters who are interested in increasing Syria-facing activities may need to wait a few months to see exactly how BIS implements the revocation of Syria's SST status. They will then need to carefully analyze the modified controls and license exception availability, as an arms embargo and other restrictive measures may remain.

Implications for Victims of Torture and Terrorism

The announcement of a planned end to Syria's SST status also establishes a new and fast-approaching deadline for U.S. victims of the Assad regime to initiate claims in federal court for acts of torture or terrorism committed by Syria.

A nation's SST designation can have life-changing ramifications for U.S. nationals who are victims of foreign terrorism and torture. The doctrine of sovereign immunity typically prevents individuals from bringing lawsuits against foreign nations, even if those nations are guilty of torture and murder. However, the "terrorism exception" to the Foreign Sovereign Immunities Act (FSIA), 28 U.S.C. §1605A, allows U.S. nationals to bring civil lawsuits against SSTs for personal injury or death caused by torture, extrajudicial killing, aircraft sabotage, or hostage taking. Victims of foreign torture and terrorism and their families have collectively won billions of dollars in civil damages in cases brought under this exception. In recent years, courts have applied the FSIA torture exception to award extensive damages to U.S. citizens who were imprisoned, tortured, and murdered by the Assad regime. 

The removal of Syria's SST designation will inevitably impact U.S. citizen victims of torture and terrorism and their family members who have potential claims against Syria. According to 28 U.S.C. § 1605A(2), lawsuits under the FSIA exception may proceed even if the nation loses its SST status after the lawsuit is commenced. The FSIA also provides a six-month grace period to bring new claims after SST designation is lifted. See id. Assuming State proceeds to remove Syria's SST designation on the announced timeline, all new FSIA claims against Syria will be cut off as of February 22, 2027. 

Syria's de-designation may also impact the amount available for claimants who prevailed in lawsuits against Syria and other SSTs. In 2003, after the fall of Saddam Hussein's regime in Iraq, State lifted sanctions, including Iraq's SST designation, in recognition of the "fundamental change in leadership and policies of the Government of Iraq" and its commitment not to support acts of international terrorism. Following this change, the U.S. government sought to return impounded Iraqi assets for use in rebuilding the Iraqi economy, making those assets unavailable to U.S. claimants.³ Because judgments under the terrorism exception are typically recovered from a U.S. fund that is financed in part by impoundments from SSTs, any similar effort to withhold Syrian assets from the fund could reduce the amount available for future claimants, at least in the short term. 

These effects would be magnified if comparable sanctions relief is applied to Iran or other SSTs in upcoming months, as appears likely. Although the military conflict in Iran is ongoing, peace discussions have centered around the possibility of lifting U.S. sanctions on Iran in exchange for concessions, with a June 2026 MOU committing the U.S. "to ending... all types of sanctions currently facing the Islamic Republic of Iran." In future peace discussions, Iran is likely to seek an end to what it has characterized as "illegal actions" brought under the FSIA exception to sovereign immunity, as it has in the past.
 
For victims of international torture or terrorism who have potential claims against current SSTs, the announced plan to normalize relations with Syria is a strong incentive to bring claims quickly before the clock runs out. U.S. nationals who have suffered imprisonment, torture, or terrorism caused by an SST's actions, and their families, should seek qualified legal guidance on their options in the upcoming months and file claims promptly when warranted in order to preserve their right to compensation. 

Miller & Chevalier is a Washington, DC, law firm with a global perspective and leading practices in Litigation, White Collar Defense and Investigations, International Law, and Business & Human Rights. Our litigation team is at the forefront of holding terrorist nations such as Iran and Syria accountable for their atrocities against U.S. citizens. The firm represents victims of torture by state sponsors of terrorism and files suit in U.S. federal court to hold such countries accountable for their crimes. 

For more information, please contact:

Bradley E. Markano, bmarkano@milchev.com, 202-626-6061

Melissa Burgess, mburgess@milchev.com, 202-626-5914

Cody Marden, cmarden@milchev.com, 202-626-1495

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¹See 22 USC § 2371.

²De minimis rules are a feature of the EAR which subjects exports of items produced abroad to U.S. export controls when they contain specified quantities of U.S.-origin content.

³See Acree v. Republic of Iraq, 276 F. Supp. 2d 95, 97 (D.D.C. 2003), rev'd, 370 F.3d 41 (D.C. Cir. 2004) (discussing U.S. efforts to recover impounded amounts).

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