On May 23, 2025, the U.S. Departments of State (“State”) and the Treasury (“Treasury”) took actions that resulted in immediate sanctions relief for Syria. Specifically, Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License 25 (“GL 25”) pursuant to the Syrian Sanctions Regulations (“SySR”), the Weapons of Mass Destruction Proliferators Sanctions Regulations (“NPWMD”), the Iranian Financial Sanctions Regulations (“IFSR”), the Global Terrorism Sanctions Regulations (“GTSR”), and the Foreign Terrorist Organization Sanctions Regulations (“FTOSR”). In parallel, Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and State took supporting actions outlined below.

Treasury’s press release explained that the sanctions relief is intended to “facilitate activity across all sectors of the Syrian economy,” in order to “help rebuild Syria’s economy, financial sector, and infrastructure.”

Treasury’s press release also emphasized that sanctions relief was extended “with the understanding that the country will not offer a safe haven for terrorist organizations and will ensure the security of its religious and ethnic minorities.”

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Photo of Dj Wolff Dj Wolff

David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with Crowell Global Advisors, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice

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David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with Crowell Global Advisors, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice focuses on all aspects of compliance with U.S. economic sanctions, including day-to-day compliance guidance, developing compliance programs, responding to government inquiries, conducting internal investigations, and representation during civil and criminal enforcement proceedings. Dj works regularly with non-U.S. clients, both in Europe and Asia, to evaluate the jurisdictional reach of U.S. sanction authorities to their global operations, identify and manage the potential conflict of laws that can result from that reach, as well as to support client’s design, implementation, and evaluation of a corresponding risk-based sanctions compliance program. Dj also regularly leads teams in diligence efforts on trade and related regulatory areas on behalf of his U.S. and non-U.S. clients in the M&A arena, having successfully closed more than 30 deals with an aggregate valuation of several billion dollars over the last 18 months.

Dj is ranked by Chambers USA in International Trade: Export Controls & Economic Sanctions. He has previously been recognized by Law360 as a Rising Star in International Trade (2020), by The National Law Journal as a “DC Rising Star” (2019), by Who’s Who Legal: Investigations as a “Future Leader” (2018 and 2019), Acritas Star as an Acritas Stars Independently Rated Lawyers (2019), by Global Investigations Review as one of the “40 under 40” in Investigations internationally (2017), and WorldECR as one of the five finalists for the WorldECR Young Practitioner of the Year award (2016).

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Photo of Erik Woodhouse Erik Woodhouse

Erik Woodhouse is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Financial Services groups, where he provides in-depth experience and practical solutions on sensitive economic sanctions and anti-money laundering matters, informed by his

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Erik Woodhouse is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Financial Services groups, where he provides in-depth experience and practical solutions on sensitive economic sanctions and anti-money laundering matters, informed by his experience in private practice and in government at the Department of the Treasury and the Department of State.

Erik works with U.S. and foreign clients operating across borders on all aspects of these regimes, including developing and assessing compliance programs, advising on complex statutory and regulatory requirements, and leading companies through internal and government investigations. He has worked with major manufacturing and tech companies with global operations, multinational banks, investment funds and other financial services firms, and digital assets and virtual currency companies, collaborating with Crowell’s cross-disciplinary team that comprises former senior regulators, federal prosecutors, and in-house counsel.

Prior to joining Crowell, Erik served as Deputy Assistant Secretary of State for Counter Threat Finance and Sanctions at the Department of State, where he played a key role in the Department’s policy development and implementation related to all U.S. country-based sanctions programs and a range of global programs. Erik worked with counterparts across the executive branch to establish and implement new sanctions programs, coordinated U.S. sanctions policy with foreign governments, and engaged with private sector stakeholders on a range of U.S. sanctions priorities. Erik’s prior government experience also includes service at the Department of the Treasury’s Office of International Affairs.

Earlier in his career, Erik worked as a project finance attorney and litigator, as a law clerk for the Honorable M. Margaret McKeown of the U.S. Court of Appeals for the Ninth Circuit, and as a research fellow at Stanford University’s Program on Energy & Sustainable Development.

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Photo of Carlton Greene Carlton Greene

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering…

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.

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Robert Clifton Burns

Robert Clifton Burns is a senior counsel in Crowell & Moring’s Washington, D.C. office. Clif focuses his practice on export controls, economic sanctions, customs, national security, and the Foreign Corrupt Practices Act. He represents clients in France, Germany, the Netherlands, Australia, and the

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Robert Clifton Burns is a senior counsel in Crowell & Moring’s Washington, D.C. office. Clif focuses his practice on export controls, economic sanctions, customs, national security, and the Foreign Corrupt Practices Act. He represents clients in France, Germany, the Netherlands, Australia, and the United States.

His clients are in a broad range of industries including medical devices, military equipment, financial services, travel and hospitality, and agriculture. Clif counsels clients on compliance matters as well as, in handling internal investigations, voluntary disclosures, and criminal defense. In addition, he represents M&A clients in international transactions with national security implications before the Committee on Foreign Investment in the United States.

Clif’s export control work encompasses a broad range of areas and includes matters involving the Export Administration Regulations administered by the Department of Commerce, the International Traffic in Arms Regulations administered by the State Department, and the country-based economic sanctions program administered by the Office of Foreign Assets Control of the Treasury Department. He also has experience in developing compliance programs for each of these three regulatory schemes, conducting due diligence for compliance with these schemes, and submitting voluntary disclosures of prior unlicensed exports.

Clif was an adjunct professor of law at the Georgetown University Law Center from 2004 until 2016. He was editor-in-chief of the Northwestern University Law Review and a law clerk for the Honorable Robert A. Sprecher with the U.S. Court of Appeals for the Seventh Circuit.

He speaks fluent French.

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Photo of Jeremy Iloulian Jeremy Iloulian

Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to

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Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to U.S. export controls (EAR and ITAR), economic sanctions, anti-boycott laws, the Committee on Foreign Investment in the United States (CFIUS), and various national security controls on fundamental research and supply chains.

Jeremy has extensive experience counseling U.S. and non-U.S. clients, including public and private companies, private equity sponsors, and nonprofits spanning a multitude of industries, including aerospace and defense, energy, entertainment, fashion, food and beverage, health care, infrastructure, technology, telecommunications, and transportation. He provides strategic guidance on managing risks for dealings in high-risk jurisdictions such as China, Russia, Venezuela, and the Middle East, among other countries and regions. He regularly advocates on behalf of such clients before the U.S. Bureau of Industry and Security (BIS), Directorate of Defense Trade Controls (DDTC), Office of Foreign Assets Control (OFAC), Bureau of Economic Affairs (BEA), Census Bureau, Department of Energy, and Nuclear Regulatory Commission (NRC).

Additionally, Jeremy has previously counseled on, presented on, and published research related to international environmental law, specifically the United Nations Convention on the Law of the Sea (UNCLOS) and Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).

Prior to and during law school, Jeremy interned at multiple government agencies, including the United Nations, the U.S. State Department, and the Iraqi Embassy in Washington, D.C.

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Photo of Dilan Wickrema Dilan Wickrema

Dilan Wickrema advises clients with respect to U.S. export controls, economic sanctions, the foreign military sales process, the Committee on Foreign Investment in the United States (CFIUS), and related investigations. Dilan leverages his experience from his various roles at the intersection of international

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Dilan Wickrema advises clients with respect to U.S. export controls, economic sanctions, the foreign military sales process, the Committee on Foreign Investment in the United States (CFIUS), and related investigations. Dilan leverages his experience from his various roles at the intersection of international trade and national security in the federal government to ensure clients meet their cross-border transaction goals while complying with the applicable laws and regulations. Previously, Dilan served in the Directorate of Defense Trade Controls (DDTC), the Bureau of Industry and Security, and the International Trade Administration.

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