Washington has dismantled the Syria sanctions architecture but nobody can date the first certification

The architecture is essentially gone. On 24 August the State Department rescinded Syria’s State Sponsor of Terrorism designation; its advisory, “Sanctions and Export Controls Relief for Syria,” states that the United States no longer imposes comprehensive sanctions on Syria and Syrian institutions and that US sanctions no longer act as a barrier to most business there. The Caesar Act itself was repealed outright on 18 December 2025 by section 8369 of the FY2026 NDAA. Residual designations survive around Assad personally, captagon traffickers, and persons linked to ISIS and al-Qaeda, per the law firm Curtis. The commercial signal is already moving: Al Jazeera reported on 25 August that Syria’s civil aviation authority had announced regular Syrian Airlines flights from Damascus to Copenhagen and Vienna beginning 21 September. France 24 Arabic devoted a programme on 4 September to what Syria builds after leaving the list.

The conditionality is where the reporting stops. Just Security reads section 8369 as requiring the President to certify to Congress every 180 days for four years on conditions including action against ISIS, removal of foreign fighters from the Syrian government, and religious and ethnic protections. Karam Shaar Advisory describes a 120-day cycle against six conditions, adding peaceful regional conduct including with Israel and credible investigations into abuses committed after December 2024. The likeliest explanation for the divergence is that one reading describes the Graham–Van Hollen Senate amendment, which would have suspended rather than repealed. The Files is not publishing either figure until the enacted text is read. Against this, Security Council Report’s August forecast records that only one third of the 2026 humanitarian appeal is funded.

Two of the conditions in every version of the list — foreign fighters in government, and protections for minorities — run straight into a file with no visible mechanism. The Congressional Research Service notes that the January 2026 agreement with the SDF calls for integrating some personnel into Syrian security force units, but that specific plans for implementation, command and vetting have not been announced. Seven months after France’s foreign ministry welcomed the signing on 30 January, the silence is the finding. CRS also records that Resolution 2799 delisted President Ahmed al-Sharaa and interim interior minister Anas Khattab from the UN’s ISIS and al-Qaeda sanctions list in November 2025, while HTS itself remained listed as of February 2026.

Assessment: The gap to watch is between relief that has already been granted and conditions that have not yet been tested. Sanctions removal is done and largely irreversible in practice; certification is a future event whose date the public record does not fix. That asymmetry favours Damascus in the short run and Congress in the long run, and it is why the enacted text of section 8369 matters more than any statement made about it. Distrust the reconstruction optimism until disbursement is visible: an unfunded appeal, an undisclosed integration mechanism and a still-listed HTS are the three measures of how far rehabilitation has actually travelled.