Washington repealed Caesar with five conditions attached, and nobody has audited the first report

The Caesar Syria Civilian Protection Act of 2019 was repealed when President Trump signed the FY2026 National Defense Authorization Act on 18 December 2025. The law firm Curtis, Mallet-Prevost places the repeal at Section 6211 in a client note dated 22 December 2025; Just Security, writing on 25 June 2026, places it at Section 8369. The two cannot both be right, and The Files has not resolved the discrepancy against the enrolled text. What is primary and unambiguous is OFAC’s own record: the Treasury confirms the repeal date and states that it removed the Syrian Sanctions Regulations, 31 CFR part 542, from the Code of Federal Regulations on 25 August 2025, following revocation of six executive orders. The Syrian Network for Human Rights published a compliance analysis of the secondary-sanctions repeal on 19 December 2025.

The conditionality is the part nobody is tracking. Per Just Security, the repeal provision requires the President to report to Congress every 180 days for four years, certifying that Syria’s government is acting against ISIS and other terrorist groups; removing foreign fighters from its ranks; upholding religious and ethnic minority rights; not taking unilateral, unprovoked military action against its neighbours, Israel included; and implementing the 10 March 2025 agreement with the SDF. If the clock runs from 18 December 2025, the second certification falls due around mid-December 2026. The Files has found no reporting on whether the first was issued, what it said, or whether Congress received it. Conditions three and five are the load-bearing ones, and both are contested facts on the ground rather than paperwork.

Two claims circulating in Syrian state media this week are not in this edition, and the reason is worth stating. SANA’s sidebar furniture on 14 September carries headlines asserting that a US removal of Syria from a terror list marks a pivot to regional stability, and that World Bank grants signal a reopening of financial ties. Neither article could be retrieved; neither has a date, a figure or an identifiable underlying action. Just Security was already discussing removal of the State Sponsor of Terrorism designation in June 2026, so the first may be older copy resurfacing. For context on where the delisting question stands: Security Council Report records that in December 2025 the UN Security Council removed al-Sharaa, Interior Minister Anas Khattab and Hay’at Tahrir al-Sham from the 1267/1989/2253 list after a Council visit to Damascus.

Assessment: Sanctions relief is usually read as a switch. This one is a subscription with renewal terms, and the terms are precisely the disputes Damascus most wants closed: minority protection and the Kurdish file. That makes the certification a documentary artefact worth chasing — it forces an administration to write down, on the record, what it believes about Syrian conduct. The absence of any reporting on the first report is the gap. It also frames the trade mission in the lead story: American capital is moving on relief that Congress can, on paper, claw back twice a year for another three and a half years.