Recent developments with regard to EU sanctions against Syrian regime: Extension and amendments

By Brian Mulier, Goran Danilovic


On 28 May 2015, the Council of the European Union (hereafter "Council") responded to the on-going deteriorating situation in Syria by adopting new measures with regard to existing EU sanctions against the Assad regime. In an attempt to maintain pressure on the Syrian regime the Council extended the existing sanctions regime against Syria for a year. Furthermore, the Council aligned certain EU sanctions with a recent UN regulation and updated the list of designated natural and legal persons, entities and bodies.

In specific, the measures are as follows:

  • The duration of existing restrictive measures against Syria was extended until 1 June 2016 by amending Decision 2013/255/CFSP. In practice, this means that the existing sanctions, including the oil embargo and the restrictions on certain investments, will continue to be applicable for the set period of time.
  • On 12 February 2015 the United Nations Security Council adopted resolution UNSCR 2199. In that regard, paragraph 17 deals with the prohibition on trade in illicitly removed property of cultural heritage and introduces a specific date of applicability:
    • "Member States shall take appropriate steps to prevent the trade in Iraqi and Syrian cultural property and other items of archaeological, historical, cultural, rare scientific and religious importance illegally removed from Iraq since 6 August 1990 and from Syria since 15 March 2011."
    • In order to align the EU sanction regime against Syria with the above newly established date Council Regulation (EU) 2015/827 of 28 May 2015 provides for an amendment to Article 11c paragraph 2 point (a) of the main Council Regulation (EU) No 36/2012. In practice this means that the EU prohibition now includes trade of abovementioned property removed on or after 15 March 2011.
  • By Council Decision (CFSP) 2015/837 of 28 May 2015 the Council amended and updated also the list of natural and legal persons, entities and bodies subject to restrictive measures as set out in Annex II to Council Regulation (EU) No 36/2012. In specific, the Council added a high ranking military official and removed Rustum Ghazali. Furthermore, the Council gave effect to the judgments of the General Court in 2014 by removing Mazen Al-Tabbaa and Bassam Sabbagh from the list of persons subject to restrictive measures.

As a general note, please be aware that non-compliance or circumvention of the EU sanction regime against Syria may lead to financial penalties and/or, in some EU Member States, be regarded as a criminal offence.



Image of Goran Danilovic

Goran Danilovic


Call me on: +31 (0)70 353 8800
Image of Brian Mulier

Brian Mulier


Call me on: +31 (0)70 353 8800