Order Amending the General Permit Allowing Specified Activities and Transactions that Are Prohibited Under the Special Economic Measures (Syria) Regulations: SOR/2025-164
Canada Gazette, Part II, Volume 159, Number 19
Registration
SOR/2025-164 August 27, 2025
SPECIAL ECONOMIC MEASURES ACT
The Minister of Foreign Affairs issues the annexed Order Amending the General Permit Allowing Specified Activities and Transactions that Are Prohibited Under the Special Economic Measures (Syria) Regulations under paragraph 2(b) of the Special Economic Measures Permit Authorization Order footnote a and subsection 4(5)footnote b of the Special Economic Measures Act footnote c.
Ottawa, August 25, 2025
Anita Anand
Minister of Foreign Affairs
Order Amending the General Permit Allowing Specified Activities and Transactions that Are Prohibited Under the Special Economic Measures (Syria) Regulations
Amendment
1 Section 2 of the General Permit Allowing Specified Activities and Transactions that Are Prohibited Under the Special Economic Measures (Syria) Regulations footnote 1 is replaced by the following:
360 days
2 This General Permit ceases to have effect on the 360th day after the day on which it comes into force.
Coming into Force
Registration
2 This Order comes into force on the day on which it is registered.
REGULATORY IMPACT ANALYSIS STATEMENT
(This statement is not part of the Order.)
Issues
Economic sanctions against Syria were first imposed under the Special Economic Measures Act (SEMA) in May 2011 as a response to the Assad regime’s violent crackdown on Syrians seeking democracy and respect of human rights. Following the fall of the Assad regime and the end of the civil war in December 2024, there is now broad international support for an inclusive Syrian-led, Syrian-owned political transition. As part of this approach, Canada issued the General Permit Allowing Specified Activities and Transactions that Are Prohibited Under the Special Economic Measures (Syria) Regulations (the General Permit) on February 28, 2025, temporarily allowing for six months specific humanitarian transactions with Syrians and Syrian institutions, including the Central Bank of Syria and six state-owned banks.
Since the General Permit was introduced, organizations have used it to provide crucial emergency aid to Syrians. This includes delivering food, clothing, and shelter supplies, especially to those affected by the 2023 earthquake. Further, it allowed emergency digital assistance to support gender-based violence issues to Syrian civil society groups, media, women and children.
The measures of the General Permit expire on August 27, 2025. To continue contributing to a sustainable and inclusive political resolution to the Syrian conflict, increasing humanitarian assistance, fostering good governance and promoting accountability for atrocities and human rights violations in Syria, Canada seeks to extend the validity of the General Permit for a period of six months.
Background
Protests for democratic reforms began in March 2011 in various cities across Syria. The violent crackdown by the Assad regime on peaceful protesters led to large-scale civilian death, injury and displacement. It is estimated that well over 350 000 people died in the conflict from 2011 to 2024, with hundreds of thousands more wounded. The situation in Syria remains one of the world’s largest displacement crises, with more than 7.2 million internally displaced Syrians and 6.2 million Syrian refugees around the world, including in neighbouring countries Jordan, Lebanon, Türkiye, Iraq as well as Egypt. The actions of the Assad regime caused a grave breach of international peace and security and resulted in an unprecedented humanitarian crisis in the region.
In response to these actions, Canada imposed a broad range of restrictions against the now-former Syrian regime in 2011 and has since made thirteen amendments to the Special Economic Measures (Syria) Regulations (the Syria Regulations), the most recent of which was in April 2017. The Syria Regulations restrict persons (individuals and entities) in Canada and Canadians outside Canada from dealing in property, providing or acquiring financial services, taking part in financial transactions, and providing goods or other services to any person listed in Schedule 1 of the Syria Regulations, which includes nearly 300 individuals and 56 entities. Furthermore, the United Nations (UN) Security Council put in place counterterrorism sanctions that relate to Syria. For instance, Hayat Tahrir al-Sham (HTS) and Jaysh al-Muhajirin wal-Ansar (JMA) are designated terrorist groups and subject to sanctions (arms embargo, travel ban, asset freeze) further to decisions of the ISIL (Da’esh) and Al-Qaida Sanctions Committee (under UN Security Council Resolutions 1267/1989/2253). By default, Canada implements UN Security Council resolutions into domestic law through the development of regulations under the United Nations Act (UNA), with the listings of individuals and entities incorporated by reference. In the particular case of HTS, its listing as a terrorist organization under the Criminal Code satisfies Canada’s international legal obligations under the UN sanctions regime. While entities are listed under the Criminal Code, they are carved out of application of the UNA.
Post-fall of the Assad regime
On December 8, 2024, opposition forces led by HTS succeeded in ending the rule of the Assad regime in Syria. An HTS-led transitional government has now been formed and is making efforts to put Syria on the path towards political stabilization and a peaceful transition. However, the security landscape remains fragile and complex, with various armed groups continuing to exert control in some parts of the country.
It is estimated that over 16 million people — approximately 70% of the country’s population — continue to urgently require humanitarian assistance. The Syria Regulations include a humanitarian exemption to carry out limited humanitarian assistance for the purpose of safeguarding human life, disaster relief, democratization, stabilization or providing food, medicine or medical supplies or equipment, but only to or by an international organization with diplomatic status, a UN agency, the International Red Cross and Red Crescent Movement, or a non-governmental organization that has entered into a grant or contribution agreement with Global Affairs Canada. The limitations of the humanitarian exemption, combined with the extensive sanctions measures related to Syria, are hindering the direct and broader humanitarian aid that could be offered by Canadians to bolster support and contribute to stabilization and a sustainable transition.
International response to the fall of the Assad regime
On December 12, 2024, G7 leaders reaffirmed their commitment to the people of Syria and full support for an inclusive Syrian-led and Syrian-owned political transition process in the spirit of the principles of UN Security Council Resolution 2254, which called for a ceasefire and political settlement in Syria as a means to end the civil war. They also called on all parties to preserve Syria’s territorial integrity and national unity and to respect its independence and sovereignty.
Since December 2024, the United States (U.S.), the United Kingdom (U.K.), the European Union (EU), and others have expressed a willingness to contribute to humanitarian assistance for the Syrian people during this period of transition.
- On February 13, 2025, France hosted the Paris Conference on Syria. On February 15, G7 Foreign Ministers met on the margins of the Munich Security Conference for the first time under Canada’s 2025 Presidency and welcomed the outcomes of the Paris Conference. On both occasions, Canada, along with like-minded countries, reiterated a commitment to the people of Syria and support for an inclusive political transition process, in the spirit of UN Security Council Resolution 2254.
- To support Syria’s recovery, in March and April 2025, the U.K. delisted 36 Syrian entities from their sanctions list, including the Central Bank of Syria and state banks, ministries, Syrian Air, and state entities involved in the oil and gas sector. On April 24, 2025, the U.K. tabled regulatory changes to remove restrictions on the financial services and energy production sectors to facilitate investment in Syria’s energy infrastructure, while maintaining measures to hold Assad and his associates to account.
- On May 28, 2025, the EU adopted legal acts to lift all economic sanctions on Syria, while maintaining those related to the Assad regime and human rights violations, as well as restrictions related to security, chemical weapons and the illicit drug trade. Further, building on earlier actions, the EU delisted 24 additional entities, including those operating in key sectors to help facilitate economic recovery.
- On June 30, 2025, President Trump signed an executive order effectively terminating the U.S. economic sanctions program against Syria. This action revoked multiple national emergency declarations and five prior executive orders, removing broad-based sanctions that had isolated Syria from the global financial system. U.S. sanctions remain on those linked to the Assad regime, terrorist organizations, and military and intelligence sectors. The executive order also directed State Department officials to “explore avenues for sanctions relief at the UN.” On July 8, 2025, the U.S. revoked its designation of HTS as a foreign terrorist organization (FTO) as part of its broader strategy to re-engage with Syria and support its reconstruction. Syria remains designated by the U.S. as a State Sponsor of Terrorism, a designation in force since December 29, 1979.
Canada’s response to the fall of the Assad regime
Canada welcomed the end of the Assad regime in Syria on December 8, 2024. Canada announced further government funding on January 13, 2025, for assistance to be delivered through the UN and experienced humanitarian partners to address urgent needs in Syria. The funding will help provide clean water and food; protection services, including for the prevention and mitigation of and response to gender-based violence; sanitation and hygiene services; and health services.
On February 28, 2025, Canada issued the General Permit, which temporarily allows all Canadians to carry out specific humanitarian transactions with Syrians and Syria, including with the Central Bank of Syria and six other state banks.
Upon the fall of the Assad regime, Canada resumed diplomatic engagement with the Syrian authorities and began regular visits to Damascus at the working level in January. On February 7, 2025, then-Prime Minister Justin Trudeau announced the appointment of the Honourable Omar Alghabra as Canada’s Former Special Envoy for Syria. On March 12, 2025, Canada nominated its Ambassador to Lebanon to serve concurrently as the non-resident Ambassador to Syria. On August 5, 2025, Canada’s Ambassador to Lebanon met with Syrian Foreign Minister Asaad Hassan al-Shaibani and the Governor of the Central Bank in Damascus.
Objective
The Order Amending the General Permit Allowing Specified Activities and Transactions that Are Prohibited Under the Special Economic Measures (Syria) Regulations (the Ministerial Order) seeks to extend the application of the General Permit, which is intended to
- temporarily ease some of Canada’s autonomous sanctions on Syria by allowing Canadians and persons in Canada to contribute to increased humanitarian-related activities in and transactions with Syria that would be otherwise prohibited under the Syria Regulations; and
- signal Canada’s support for Syrians and openness to contribute to stabilization and a sustainable political resolution of the Syrian conflict by addressing humanitarian needs.
Description
The Ministerial Order is extending the General Permit that was registered on February 28, 2025, under SEMA to allow any person (individuals and entities) in Canada and Canadian outside Canada to carry out activities and transactions that would otherwise be prohibited under the Syria Regulations in support of the delivery of humanitarian aid, democratization and stabilization regarding Syria.
Any person in Canada and Canadians outside Canada are allowed to provide any funds or services to Syria in support of the delivery of humanitarian-related aid to or within Syria, including transactions with the following seven banks currently sanctioned under the Syria Regulations:
- Commercial Bank of Syria (Schedule 1, Part 1, No. 8)
- Real Estate Bank (Schedule 1, Part 1, No. 16)
- Industrial Bank (Schedule 1, Part 1, No. 35)
- Popular Credit Bank (Schedule 1, Part 1, No. 36)
- Saving Bank (Schedule 1, Part 1, No. 37)
- Agricultural Cooperative Bank (Schedule 1, Part 1, No. 38)
- Central Bank of Syria (Schedule 1, Part 1, No. 39)
At the time it entered into force on February 28, 2025, the General Permit’s initial validity period was set to be for a period of 180 days. Through the current Ministerial Order, the General Permit’s validity period is now being extended for an additional six months.
For any activity or transaction outside the scope of the General Permit mentioned above, persons in Canada or Canadians outside Canada are prohibited from dealing in the property of, entering into transactions with, providing services to, transferring property to, or otherwise making goods available to listed persons under the Syria Regulations. Other prohibitions under the Criminal Code as well as pursuant to UN Security Council resolutions may still apply for humanitarian-related and other activities. Additional information is available in the FAQs available on the Canadian sanctions web page of Global Affairs Canada’s website.
Regulatory development
Consultation
Global Affairs Canada regularly engages with relevant stakeholders, including civil society organizations, cultural communities, and other like-minded governments, regarding Canada’s approach to sanctions implementation. Additionally, Global Affairs Canada engages with relevant stakeholders, including civil society organizations and financial institutions, regarding sanctions compliance as well as individual permit applications and authorizations.
In recent months, since the fall of the Assad regime, stakeholders and subject matter experts have called for increased Canadian assistance in response to the humanitarian needs in Syria. Although all Canadians are allowed to use the General Permit, it is expected that stakeholders benefitting from this measure will primarily be civil society organizations, non-profit organizations, charitable organizations, or individuals and groups from the Syrian diaspora in Canada wanting to send funds or offer services to boost humanitarian assistance in Syria. This regulatory development should not have any adverse impact on relevant stakeholders given that the General Permit as it is being amended continues to ease restrictions and to temporarily remove barriers on specific humanitarian-related activities and transactions regarding Syria.
Public consultation pertaining to the General Permit would not have been appropriate or possible due to sensitive foreign policy considerations and time pressures to support a sustainable transition in Syria. Through the implementation of the General Permit and other engagement related to Syria, Canada will remain engaged and exchange views with stakeholders on how Canadian efforts can best support the immediate delivery of humanitarian assistance to Syria.
Modern treaty obligations and Indigenous engagement and consultation
In accordance with the Cabinet Directive on the Federal Approach to Modern Treaty Implementation, an initial assessment of the geographical scope of the amendments was conducted to determine whether the amendment would give rise to modern treaty implications, duty to consult obligations, or obligations under the United Nations Declaration on the Rights of Indigenous Peoples Act. No implications or modern treaty obligations were identified, as the amendments do not take effect in a modern treaty area.
Instrument choice
Under SEMA, sanctions are imposed and lifted by amending regulations. Therefore, regulations are the only available legal instrument for repealing prohibitions or lifting certain prohibited measures under SEMA. No other instruments could be considered.
Regulatory analysis
Benefits and costs
Canadians seeking to take advantage of the General Permit are expected to be civil society organizations, non-profit organizations, charitable organizations, or individuals and groups from the Syrian diaspora in Canada. The General Permit allows specific activities and transactions that would otherwise be prohibited under the Syria Regulations.
The extension of the General Permit will continue to temporarily lift certain restrictions for stakeholders to provide humanitarian-related aid to Syria. Extending the General Permit should not have any adverse impact on relevant stakeholders and is expected to have a positive impact on both Canadian organizations that will be able to undertake additional humanitarian-related activities or transactions and on the citizens of Syria who will benefit from the humanitarian support.
Canadian banks and financial institutions are required to comply with sanctions. Since the measures are extended, these institutions will simply need to update the validity date of the General Permit in their existing monitoring systems, which may result in a negligible compliance cost.
The incremental cost to the Government of Canada to continue implementing and administering the General Permit is minimal.
Small business lens
Analysis under the small business lens concludes that extending the General Permit will not impact Canadian small businesses. It is anticipated that primarily non-business entities and organizations would be implicated in humanitarian-related activities in Syria. Should a small business wish to participate in humanitarian-related activities in Syria, the General Permit will continue to temporarily lift the requirement to apply for a permit under the Syria Regulations, although the activities could be subject to any other relevant prohibitions under the Criminal Code as well as UN Security Council resolutions. Other obligations included in the Syria Regulations, such as the duty to disclose, remain in place.
One-for-one rule
The one-for-one rule does not apply, as there is no incremental change in administrative burden on stakeholders interested in benefiting from the General Permit. No regulatory titles are repealed or introduced. It is anticipated that primarily non-business entities and organizations would be implicated in humanitarian-related activities in Syria. The General Permit will continue to temporarily lift the requirement to apply for a permit under the Syria Regulations, though the activities could be subject to any other relevant prohibitions under the Criminal Code as well as UN Security Council resolutions.
Regulatory cooperation and alignment
Extending the General Permit aligns Canada’s efforts with those of the U.S., the U.K., the EU, and others. While the Ministerial Order is not related to a work plan or commitment under a formal regulatory cooperation forum, it aligns with actions taken or announced by some of Canada’s allies, including the EU, the U.K., and the U.S.
International obligations
Compliance with Canada’s international obligations was considered in the development of this proposal.
As a Member State of the UN and pursuant to article 25 of the United Nations Charter, Canada is legally obligated to implement binding decisions of the UN Security Council taken under Chapter VII. These decisions include measures other than the use of force (e.g. asset freeze, travel ban, arms embargoes) to maintain or restore international peace and security where a threat to the peace, breach of the peace, or act of aggression exists. Global Affairs Canada coordinates with the Department of Justice to implement these resolutions into domestic law, usually through the development of regulations under the UNA. Canada has implemented the decisions of the 1267/1989/2253 ISIL (Da’esh) and Al-Qaida Sanctions Committee of the UN Security Council by establishing the Regulations Implementing the United Nations Resolutions on the Taliban, ISIL (Da’esh) and Al-Qaida. However, in the cases of the UN sanctions against HTS and JMA, Canada has implemented its international obligation to apply sanctions through a listing as terrorist entities under the Criminal Code.
Effects on the environment
Renewing the Ministerial Order is unlikely to result in important environmental effects. In accordance with the Cabinet Directive on Strategic Environmental and Economic Assessment (SEEA), a preliminary scan concluded that a SEEA is not required.
Gender-based analysis plus
The subject of economic sanctions has previously been assessed for effects on gender and diversity. Although intended to facilitate a change in behaviour through economic pressure on individuals and entities in foreign states, sanctions under SEMA can nevertheless have an unintended impact on certain groups and individuals in vulnerable situations. Targeted sanctions limit the collateral effects to those dependent on listed individuals and entities and are unlikely to have a significant negative impact on vulnerable groups as compared to traditional broad-based economic sanctions directed toward a state. Furthermore, this General Permit, by maintaining the lift on some restrictions to allow greater humanitarian support, is expected to have a positive impact for the citizens of Syria, including vulnerable groups.
Implementation, compliance and enforcement, and service standards
Implementation
The Ministerial Order comes into force on the day it is registered.
Compliance and enforcement
The Trade Commissioner Service at Global Affairs Canada continues to assist clients in understanding Canadian sanctions regulations and, notably, the impact of the Syria Regulations on any activities in which Canadians may be engaged, abroad and in Canada. Global Affairs Canada is also increasing outreach efforts across Canada — including engaging with businesses, universities, and provincial and territorial governments — to enhance national awareness of and compliance with Canadian sanctions.
Under the SEMA, both Royal Canadian Mounted Police and Canada Border Services Agency officers have the power to enforce sanctions violations through their authorities, as defined under the Customs Act, the Excise Act or the Excise Act, 2001, and the Criminal Code.
In accordance with section 8 of SEMA, every person who knowingly contravenes or fails to comply with the Syria Regulations or the General Permit is liable, upon summary conviction, to a fine of not more than $25,000 or to imprisonment for a term of not more than one year, or to both; or, upon conviction on indictment, to imprisonment for a term of not more than five years.
Contact
Global Affairs Canada
Sanctions Bureau
125 Sussex Drive
Ottawa, Ontario
K1A 0G2
Email: sanctions_permits-permis@international.gc.ca
Telephone (toll-free): 1‑833‑352‑0769
Telephone (local): 1‑343‑203‑3975