Prospects for Syrian Civil Society Remain Dim While Sanctions Linger
In March 2025, Syrian civil society actors, European officials, and European and American policy experts gathered in The Hague to assess the role of sanctions in Syria’s political and economic transition following the fall of Damascus to Hayat Tahrir al-Sham (HTS). During a one-day workshop co-hosted by the Bourse & Bazaar Foundation and the Clingendael Institute, participants discussed how Western sanctions policy should be adjusted to alleviate Syria’s desperate economic situation. The gathering focused on ensuring meaningful support to local institutions and civil society, with the ambition of preventing the country from spiraling into renewed conflict.
Syria remains under multiple overlapping sanctions regimes led by the United States, the European Union, and the United Nations. These measures—originally designed to pressure the Assad regime—now inhibit economic recovery, reconstruction, and institutional reform, even though the political landscape has shifted.
The US regime, shaped by the Caesar Act and counterterrorism designations of HTS, is the most comprehensive and extraterritorial. General License 24, set to expire in July 2025, provides narrow exemptions focused on essential services but does not allow for new investment or broader engagement. The EU has taken steps to suspend sanctions on key sectors, including energy and transport, yet the extraterritorial effect of US sanctions limits the impact of EU moves. The UN still lists HTS under its 1267 regime, restricting international financial and diplomatic engagement.
While the legal frameworks differ, the overall effect is similar: financial institutions, aid agencies, and the private sector are reluctant to engage in Syria, fearing compliance risks and political fallout.
Participants described the Syrian economy as being in a state of accelerating collapse, with deteriorating civil services, soaring unemployment, and households struggling without purchasing power. The destruction of infrastructure, ongoing currency depreciation, and the withdrawal of Russian and Iranian economic support have compounded the crisis. Streets in Damascus are flooded with cheap Turkish imports that Syrians cannot afford. Even in now stable areas of the country, public utilities and services—electricity, water, telecommunications, education—are barely functional.
Against this backdrop, humanitarian needs are escalating, yet aid pledges remain grossly inadequate. According to estimates, Syria’s reconstruction needs range between $250 and $400 billion, while the March 2025 Brussels donor conference resulted in pledges amounting to just $6.5 billion. Even early recovery and resilience programming—technically permissible under many sanctions frameworks—remains underfunded and politically delayed.
Despite the continued implementation of sanctions, participants noted that the international donor community is not entirely constrained from engaging with Syria. Under existing exemptions and mandates, there are already pathways for supporting essential services, infrastructure rehabilitation, and early recovery efforts—particularly when these activities are framed as humanitarian or development aid. According to one workshop participant, the World Bank has confirmed that it can support infrastructure and basic services in Syria under its post-conflict operational framework. However, meaningful engagement still depends on greater clarity and political alignment from member states. If expanded and adequately resourced, the Bank’s early recovery programs could offer a critical lifeline to communities even in the absence of full-scale sanctions relief.
Failure to lift or ease sanctions will prevent private sector and institutional investment that is essential for rebuilding the Syrian economy. But failure to increase aid, even under the current legal frameworks, ensures continued suffering, deepens instability, and risks the re-emergence of violence, organised crime, and extremism.
A central theme in the discussions was the counterproductive reliance on political benchmarks—such as inclusivity, constitutional reform, and governance transformation—as preconditions for sanctions relief. While these conditions seem sensible, they have triggered a rushed and top-down political process in Syria that many civil society organisations (CSOs) described as inorganic and externally driven.
For example, the national dialogue conference was announced to many of its intended participants with less than 24 hours’ notice. Consultations were limited in scope and representation, with key civic figures and regions underrepresented. Similarly, the interim constitution was drafted in just weeks, concentrating power in the executive, offering minimal separation of powers, and making vague commitments to pluralism.
HTS has made symbolic gestures to show its commitment to inclusive governance, such as appointing technocrats and making deals with Druze, southern militias, and Kurdish factions. Civil society actors view these many of these moves as superficial and tailored to meet donor expectations rather than domestic realities. Many warned that the political process risks collapsing without parallel efforts to restore economic viability and institutional functionality.
Moreover, the current sanctions framework often fails to distinguish between political conditionality and humanitarian necessity. As one participant remarked, “you cannot expect people to fight for democracy when fighting for food.”
Syrian civil society actors at the workshop identified several priorities for supporting an inclusive and grounded transition. Chief among them was the need for clearer guidance on sanctions and access to channels for clarification from relevant authorities. Many CSOs, especially those returning from abroad, are eager to establish offices in Damascus but face significant challenges due to legal uncertainties and the degraded infrastructure. Establishing local operations is constrained by the lack of electricity and internet access in particular, two utilities affected by sanctions.
Participants also emphasised the importance of providing training and technical support to ensure compliance with evolving sanctions frameworks, especially around financial procedures and institutional engagement. Access to dedicated funding with simplified disbursement processes, along with protections against bank over-compliance, was also flagged as essential.
In addition, CSOs called for increased support for local governance and service delivery, including civil servant salaries and early recovery programmes. They urged international actors to move away from a narrow focus on minority protection and instead promote a shared civic rights agenda. Finally, participants highlighted the need for more unified CSO advocacy efforts to engage international partners with a coherent voice representing diaspora and in-country actors.
Without these resources, CSOs will struggle to play a meaningful role in Syria’s constitutional reform, local governance, or transitional justice efforts. The current imbalance between international expectations and the limited capabilities of civil society risks undermining its legitimacy—not only in the eyes of donors, but also among ordinary Syrians. When CSOs are unable to address pressing socioeconomic needs like livelihoods, essential services, and infrastructure, they can appear ineffective or disconnected from the reality on the ground. As one participant noted, if civil society is perceived as focused solely on political processes while daily conditions worsen, public trust and relevance may quickly erode.
In response to these concerns, participants proposed a set of actionable steps for international actors to align sanctions policy with Syria’s evolving circumstances. For the United States, the immediate priority is to make General License 24 permanent and broaden its scope to include investment and infrastructure-related activities. Participants also urged Washington to remove HTS’ designation as a Foreign Terrorist Organisation (FTO) while maintaining its listing as a Specially Designated Global Terrorist (SDGT), at least for now. This modest move would reduce the legal risks associated with engagement while preserving necessary safeguards for the population. Alongside these steps, it was suggested the US should issue more explicit guidance on permissible engagements in Syria—such as FAQs or advisory notes tailored to humanitarian and development actors—to reduce uncertainty and risk aversion.
While the European Union has gone further than the US in suspending sanctions, it still plays a key role. Participants emphasised the need for the EU to make its current suspension of sectoral sanctions permanent and to outline a transparent roadmap towards full sanctions removal. Additionally, they recommended launching an EU-led reconstruction trust fund that is both insulated from US financial jurisdiction as well as open to co-financing from Gulf states and multilateral actors. Restoring a diplomatic and technical presence on the ground would also assist the EU in monitoring developments in Syria, ultimately supporting a more credible political and economic transition.
Crucially, the EU must actively encourage the United States to take bolder and more decisive steps. Without parallel US action, the efficacy of EU measures remains limited, especially given the extraterritorial scope of American sanctions.
Recommendations for the UN mainly focused on unlocking key legal and diplomatic barriers. Participants called for a review of HTS’s designation under the 1267 regime, taking into account its public disavowal of ties to al-Qaeda and ongoing coordination against the Islamic State. The UN Special Envoy should be mandated to engage the new Syrian authorities to negotiate specific steps toward delisting or, at a minimum, time-bound exemptions aligned with transitional goals. Furthermore, the implementation of UNSCR 2664—which establishes humanitarian carve-outs across all UN sanctions regimes—should be actively promoted and incorporated into member state legislation to improve operational clarity and access for aid providers.
The workshop underscored the sobering reality that Syria’s future depends on concrete steps from the international community to ensure a successful political transition, economic recovery, and reconstruction. Maintaining rigid conditionality while under-delivering on aid and sanctions relief will neither foster inclusive governance nor prevent future conflict. Policymakers must realign their tools with the current realities—pairing cautious diplomacy with tangible economic support and giving civil society the space and resources to lead. As one participant put it, “sanctions might have been a tool to shape Syria’s future. Today, they are part of what’s preventing it.”
Photo: Ahmed Akacha
