EU Sanctions Against Syria 2026: What Changes for Companies with Syrian Links

Key data

If your company operates with Syria, has Syrian counterparties or manages assets linked to that country, this regulatory update directly affects you. The EU Council has modified through Decision (CFSP) 2026/1105 the sanctions regime against Syria that has been in force since 2013, with effect from May 18, 2026.

This is not a new regulation: it is an update to Decision 2013/255/CFSP, the framework of restrictive measures that the EU maintains on Syria. These periodic updates typically involve changes to lists of sanctioned persons and entities, modifications to applicable prohibitions or adjustments to the conditions of existing restrictions.

What does this regulation establish?

Decision 2026/1105 modifies the EU sanctions regime against Syria within the framework of the Common Foreign and Security Policy (CFSP). Although the full text of the specific changes must be consulted in the EU Official Journal, the areas that may be affected by this type of updates are as follows:

The modified regulation, Decision 2013/255/CFSP, has been in force for more than a decade and has been subject to multiple updates. Each modification may expand or reduce the scope of applicable restrictions, so it is essential to review the current consolidated version.

Economic and operational impact

The direct impact of this update depends on the type of relationship your company maintains with Syria or with Syrian counterparties. The most relevant operational effects are:

• Financial operators: must verify that no transaction, transfer or financial product involves persons or entities that have been added to the sanctioned lists.
• Exporters and importers: must check whether the changes introduced affect the trade prohibitions applicable to their products or services.
• Companies with assets in Syria: must review whether any counterparty or partner has been included in the asset freeze lists.
• Compliance departments: must update their screening and due diligence procedures with the lists published in the EU Official Journal.

Non-compliance with EU restrictive measures is not a minor matter: it can result in serious administrative and criminal sanctions, in addition to reputational damage and blocking of operations. Spanish authorities are responsible for monitoring and sanctioning non-compliance in national territory.

Who does it affect?

This regulation affects any company or professional with direct or indirect links to Syria. Specifically:

• Exporting or importing companies with commercial activity in Syria or with Syrian counterparties
• Financial entities (banks, insurance companies, asset managers) that operate with clients or assets linked to Syria
• Logistics and transport companies with routes that include Syria
• Advisors, consultants and lawyers providing services to Syrian persons or entities
• Companies with investments, subsidiaries or shareholdings in Syria
• Any natural or legal person managing funds or assets related to listed persons
• Compliance and legal departments of business groups with exposure to Middle Eastern markets

Practical example

A Spanish industrial machinery company that maintains a supply contract with a Syrian company should act as follows after the publication of this Decision:

1. Consult the updated lists published in the EU Official Journal to verify whether the Syrian counterparty company has been added to the lists of sanctioned entities.
2. Review whether the products subject to the contract are affected by any trade prohibition modified in this update.
3. Check whether pending or future payments can be executed without violating asset freeze restrictions.
4. If there is reasonable doubt, provisionally suspend the operation and consult with a specialist in foreign trade and international sanctions before continuing.

This verification process must be carried out each time the EU updates the lists or sanctions framework, not just when initiating the commercial relationship.

What should companies do now?

1. Immediately consult the updated lists published in the EU Official Journal to identify whether any Syrian counterparty, partner or client has been included or modified in the lists of sanctioned persons.
2. Review all active contracts and transactions with Syrian parties to verify that they do not violate the restrictive measures in force following the update of May 18, 2026.
3. Update internal compliance procedures and due diligence by incorporating the new lists and restrictions into counterparty screening systems.
4. Train the team responsible for international operations, finance and legal on the changes introduced and the obligations for periodic verification.
5. Document all verifications performed to demonstrate due diligence in case of inspection or request by the competent authorities.
6. Consult a specialist in international sanctions if there is any doubt about the application of restrictive measures to specific operations, as non-compliance can result in serious administrative and criminal sanctions.