2025 Update: International Sanctions & Crypto Restrictions in Syria and Cuba
Syria vs Cuba Sanctions Comparison Tool
Syria
Sanctions relief with focus on economic engagement
- Central Bank removed from SDN List
- U.S. banks can open correspondent accounts
- Crypto exchange access increased
Cuba
Stricter sanctions with expanded scope
- CACR fully enforced
- Subsidiaries of U.S. persons affected
- Crypto-related services restricted
Key Changes in 2025
Syria: Executive Order 14312
- Revoked comprehensive sanctions
- Removed Syrian Central Bank from SDN List
- Allowed U.S. banks to provide export-related services
- Kept targeted sanctions on Assad family and captagon network
Cuba: NSPM-5
- Reinforced Cuba Assets Control Regime (CACR)
- Expanded scope to include non-U.S. subsidiaries
- Prohibited crypto-related services
- Increased enforcement penalties
Crypto Landscape
Syria
Regulatory vacuum allows crypto activity but requires AML checks:
- Binance opened Syrian fiat on-ramps
- Extra KYC documentation required
- Lightspark's Grid Switch offers off-chain solutions
- Banks perform heightened due diligence
Cuba
No formal crypto legislation; CACR blocks most crypto services:
- Major exchanges block Cuban IPs
- U.S. bank involvement triggers sanctions alerts
- Peer-to-peer platforms monitored
- FinCEN guidance requires explicit reporting
Compliance Checklist
For Syria
- Screen all counterparts against OFAC lists
- Document enhanced due diligence for crypto transactions
- Verify counterparty not on targeted sanctions list
- Flag transfers involving high-risk jurisdictions
For Cuba
- Treat CACR as blanket prohibition
- Obtain specific OFAC licenses before transactions
- Maintain separate audit logs for crypto transfers
- Follow FinCEN guidance on crypto reporting
Important Note: This tool provides educational information about U.S. sanctions policies in 2025. Actual compliance requirements may vary and should be verified with legal counsel or regulatory experts.
In July 2025 the U.S. government flipped the script on two long‑standing sanctions regimes, opening a window of opportunity for Syrian businesses while tightening the squeeze on Cuban operations. For anyone handling cross‑border payments, crypto trading, or compliance work, understanding what changed, what stayed the same, and how to navigate the new gray zones is essential.
What the 2025 policy shift looks like
President Trump issued Executive Order 14312 which revoked the 2004 executive order that imposed comprehensive sanctions on Syria and terminated the related national emergency on June 30, 2025, taking effect the next day. At the same time, the administration rolled out National Security Presidential Memorandum 5 (NSPM‑5) a directive that reinstated hard‑line sanctions on Cuba, reversing late‑Biden relaxations. The two moves were simultaneous but opposite: Syria got a broad relief, Cuba got a stricter regime.
Syria: Sanctions relief in detail
The heart of the relief was the removal of the Syrian Central Bank from the Specially Designated Nationals (SDN) List a roster of entities and individuals barred from U.S. financial transactions. Office of Foreign Assets Control (OFAC) the Treasury unit that enforces sanctions announced the change on July 1, 2025, allowing U.S. banks to open correspondent accounts with Syrian banks and to offer export‑related financial services without a license.
Importantly, the order kept targeted sanctions on the Assad family, the captagon trade network, and individuals linked to serious human‑rights violations. That means any transaction involving those listed persons still triggers a compliance alert.
Crypto landscape in Syria after the lift
Syria still has no specific law that either authorizes or bans cryptocurrencies. The regulatory vacuum forces crypto firms to lean on the existing Anti‑Money‑Laundering and Combating the Financing of Terrorism (AML/CFT) framework Syria’s legal structure for monitoring illicit finance. Because of that, platforms such as Binance one of the world’s largest crypto exchanges added Syrian fiat on‑ramps shortly after the sanctions lift, but they require extra KYC documentation.
FinTech firms have started to bridge the gap. Lightspark a blockchain‑based payment infrastructure provider launched a solution called Grid Switch that uses the Lightning Network as a settlement layer while routing fiat through domestic real‑time payment rails, reducing direct crypto exposure for regulated institutions.
Despite the new opportunities, banks still perform heightened due‑diligence. They must verify that the counterparties are not on any remaining sanctions list, and they often flag transfers that involve crypto wallets tied to high‑risk jurisdictions.
Cuba: Reinforced sanctions under NSPM‑5
While Syria saw relief, Cuba faced a rollback. NSPM‑5 re‑affirmed the Cuba Assets Control Regime (CACR) the legal framework that blocks U.S. persons and entities from dealing with Cuba. The regime now applies to non‑U.S. subsidiaries of U.S. persons, expanding the compliance perimeter.
A concrete illustration came in July 2025 when Key Holding, LLC a Delaware‑based logistics firm settled with OFAC for $608,825 after a subsidiary moved 36 freight shipments from Colombia to Cuba without proper licensing. The case underscored that even inadvertent breaches can carry hefty penalties.
Crypto restrictions in Cuba
Cuba has no formal crypto legislation either, but the CACR effectively bars most crypto‑related services. Major exchanges keep Cuban IPs blocked, and any attempt to route crypto payments through U.S. banks triggers a sanctions alert. Local entrepreneurs who try to use peer‑to‑peer platforms face constant scrutiny from Cuban authorities, who monitor crypto activity as a potential tool for capital flight.
Financial institutions that serve Cuban clients must also navigate the Financial Crimes Enforcement Network (FinCEN) the U.S. agency that collects and analyzes financial transaction data guidance, which now calls for explicit reporting of any crypto‑related transfers that could involve Cuban beneficiaries.
Side‑by‑side: Syria vs. Cuba sanctions in 2025
| Aspect | Syria | Cuba |
|---|---|---|
| Executive action | Executive Order 14312 | NSPM‑5 |
| SDN List status | Central Bank of Syria removed | CACR remains fully enforced |
| Targeted sanctions | Assad family, captagon network, human‑rights violators | Broad embargo; applies to subsidiaries of U.S. persons |
| Crypto exchange access | Binance and other major platforms opened Syrian fiat on‑ramps (with AML checks) | Most exchanges block Cuban IP; indirect access prohibited |
| Recent enforcement | None notable post‑lift (as of Oct2025) | Key Holding settlement ($608,825) for logistics violation |
Practical compliance checklist
- Run a fresh OFAC screen on every counterpart, even after the Syrian relief, to catch remaining targeted designations.
- Document enhanced due‑diligence steps (source of funds, ownership structure, sanctions‑list cross‑check) for any Syrian crypto transaction.
- For Cuban dealings, treat the CACR as a blanket prohibition unless a specific OFAC license is obtained.
- Maintain a separate audit log for crypto‑related transfers that involve high‑risk jurisdictions (Syria, Cuba, Iran, Russia).
- Leverage technology (e.g., Lightspark’s Grid Switch) that can route fiat payments while keeping crypto activity off the public ledger, reducing detection risk.
- Stay up‑to‑date with FinCEN’s 2025 guidance on crypto‑related reporting for sanctioned regions.
Looking ahead: What the next years may bring
Analysts expect the Syrian relief to spur modest foreign‑direct investment, especially in telecom and renewable‑energy projects that can be financed through crypto‑backed stablecoins. However, the targeted sanctions will likely stay in place as long as the Assad regime retains its grip on power.
For Cuba, the trend points to even tighter enforcement. The administration has hinted at expanding the CACR to cover cryptocurrency wallets owned by Cuban nationals abroad, which would force diaspora remittances onto traditional banking channels-if those channels remain open.
Overall, the divergence signals a broader U.S. strategy: use sanctions relief as a diplomatic lever in the Middle East while keeping Cuba as a bargaining chip in broader geopolitical negotiations. Crypto firms that can adapt compliance programs quickly, leverage off‑chain settlement layers, and maintain clear audit trails will be best positioned to serve both markets-if they choose to.
Frequently Asked Questions
Did the July 2025 sanctions lift completely remove Syria from OFAC’s reach?
No. While the broad embargo ended and the Central Bank was removed from the SDN List, targeted sanctions on specific individuals, the captagon trade network, and human‑rights violators remain active.
Can U.S. citizens trade Bitcoin on Binance for Syrian fiat?
Yes, but they must complete additional KYC steps, and the exchange will run an AML check to ensure no funds pass through a sanctioned Syrian entity.
What licensing is required to ship goods from the U.S. to Cuba?
A specific OFAC license (often a General or Specific License) is mandatory. Without it, even indirect shipments via a foreign subsidiary can trigger the $608k penalty seen in the Key Holding case.
How does Lightspark’s Grid Switch help with Syrian payments?
Grid Switch settles cross‑border fiat via the local real‑time payment system while using the Lightning Network only as an off‑chain settlement layer, keeping the crypto transaction invisible to traditional banking screens.
Will future U.S. administrations likely reverse the Cuban sanctions again?
It’s unpredictable. The current administration has signaled a hard stance, and any reversal would depend on broader diplomatic negotiations, especially around migration and regional security.
Cynthia Rice
Freedom is a candle lit by policy, brightening the path for Syrian merchants but dimming the Cuban sky.
Miranda Co
Take that metaphor and apply it to the compliance desk: you can’t just stare at the flame, you have to wear a fire‑proof coat. The Syrian central bank’s removal from the SDN list means banks must still screen for the Assad family sanctions. Cuba’s CACR, on the other hand, still smothers any crypto‑related attempt. So the risk profile isn’t symmetric. In short, adjust your AML controls accordingly.
Shaian Rawlins
The 2025 policy swing feels like a roller‑coaster for anyone managing cross‑border crypto flows, and you can see the excitement building in the compliance community. When the U.S. pulled the emergency on Syria, Binance wasted no time adding fiat on‑ramps, but they also asked for extra KYC paperwork, which adds friction for everyday users. Meanwhile, the Cuban embargo tightened, and most exchanges simply block IPs, forcing traders to seek peer‑to‑peer routes that are far less transparent. This duality forces firms to maintain two completely separate compliance playbooks: one that leans into enhanced due diligence for Syrian counterparties, and another that treats any Cuban interaction as a near‑automatic ban unless a specific OFAC license is in hand. The lightspark Grid Switch solution tries to bridge the gap by moving fiat through domestic rails while keeping the crypto layer off the radar, which is clever but still requires thorough audit trails. Analysts predict that Syrian foreign direct investment will slowly climb, especially in renewable energy projects backed by stablecoin financing, but the Assad‑related designations remain a thorny issue. For Cuban diaspora, the risk of triggering the CACR is high, especially if they attempt to route funds through U.S. banks, so many are reverting to cash‑based remittances. FinCEN’s 2025 guidance now explicitly calls for reporting any crypto transaction that might involve Cuban beneficiaries, adding another reporting layer. In practice, compliance teams must now juggle heightened AML checks for Syria and blanket prohibitions for Cuba, which can stretch resources thin. Overall, the landscape demands agile technology and vigilant monitoring to stay on the right side of the law.
mukesh chy
Oh great, because the U.S. just loves to play “policy seesaw” – lifting one country while smacking another, as if we’re all living in a sandbox where sanctions are just optional house rules.
Amal Al.
Listen, the compliance checklist is not a suggestion; it’s a mandate-run fresh OFAC screens on every Syrian counter‑party, document every crypto KYC detail, and treat any Cuban transaction as prohibited unless you have an OFAC license-failure to do so will result in hefty penalties!!!
Taylor Gibbs
Yo, if you’re tryna do biz in syrian crypto, just make sure u double check the lists, cuz the asad fam is still on there and a slip could get u in hot water.
Jim Griffiths
Run OFAC screen, flag high‑risk wallets, keep audit logs.
Matt Nguyen
One must consider the broader geopolitical agenda; the simultaneous relief for Syria and tightening for Cuba may serve undisclosed strategic interests beyond mere economic policy, potentially aligning with intelligence objectives aimed at leveraging crypto channels for surveillance.
Twinkle Shop
The dichotomy introduced by Executive Order 14312 and NSPM‑5 creates a bifurcated compliance architecture that necessitates a modular risk assessment framework, integrating both transaction‑monitoring analytics and entity‑resolution workflows. In the Syrian context, the removal of the Central Bank from the SDN list unlocks correspondent banking relationships, yet the persistence of targeted designations on the Assad family mandates the incorporation of sanctions‑screening tiers within the AML engine. Crypto exchanges, such as Binance, have operationalized enhanced KYC protocols by deploying multi‑factor identity verification, which dovetails with the requirement for “source‑of‑funds” attestations as stipulated by FinCEN’s 2025 guidance. Conversely, the Cuban Assets Control Regime imposes a de‑facto prohibition, compelling firms to instantiate a default‑deny rule set within their transaction monitoring system, effectively black‑listing any IP address or wallet address associated with Cuban jurisdictions. The introduction of Lightspark’s Grid Switch leverages the Lightning Network’s off‑chain settlement capabilities, enabling fiat‑backed stablecoins to traverse domestic RTGS channels while preserving cryptographic auditability. However, this architecture must be reconciled with the “beneficial‑owner” identification mandates embedded in the FATF Recommendations, thereby invoking a dual‑layer compliance overlay. From a data‑privacy standpoint, the aggregation of KYC metadata for Syrian users raises considerations under GDPR equivalency frameworks, especially when cross‑border data flows intersect with U.S. jurisdiction. Moreover, the enforcement precedent set by the $608,825 penalty against Key Holding underscores the fiscal risk calculus inherent in non‑compliant Cuban engagements. Institutions are thus advised to instantiate a sandbox environment for testing compliance controls, utilizing synthetic transaction generators to model edge‑case scenarios involving high‑risk jurisdictions. Continuous monitoring of OFAC releases, coupled with automated rule updates via API integrations, will mitigate latency in adapting to policy shifts. In sum, the operationalization of a robust, programmable compliance stack-encompassing AML, KYC, sanctions screening, and transaction monitoring-constitutes the cornerstone of navigating the divergent regulatory regimes imposed on Syria and Cuba in 2025.
stephanie lauman
Do not underestimate the legal liability; the CACR enforcement apparatus has demonstrated an alarming willingness to pursue both direct and indirect violations, as evidenced by the recent multi‑million settlement, and any deviation from prescribed licensing protocols will invite severe penalties 😡.
Greer Pitts
Guys, real talk – if you think you can just slip a crypto payment to Cuba without a license, think again; OFAC's watching and they’ll slap you with fines faster than you can say “blockchain”.
Katherine Sparks
It is incumbent upon financial institutions to meticulously document all enhanced due diligence procedures undertaken for Syrian crypto transactions, as the regulatory expectations delineated herein are unequivocally stringent; failure to comply may precipitate enforcement actions, thereby jeopardizing corporate reputational capital 😊.
Kimberly Kempken
In the grand theater of sanctions, Syria is the protagonist granted a fleeting intermission, while Cuba remains the antagonist condemned to perpetual exile, a narrative that forces us to confront the ethics of selective economic emancipation.
Eva Lee
From a compliance architecture perspective, the divergent sanction vectors necessitate a bifurcated policy engine: one module ingests Syrian AML risk scores and another enforces a hard stop on Cuban crypto interactions, ensuring governance alignment across both domains.
Rob Watts
Stay vigilant keep audit logs updated and avoid shortcuts
Natalie Rawley
Can you believe the US just pulled the rug out from under Cuba while handing Syria a golden ticket? It’s like watching two movies at once and only one has a happy ending.
Alex Gatti
what does this mean for crypto startups that are trying to serve both regions they have to pick a side or risk everything
John Corey Turner
Imagine sanctions as a stormy sea; Syria’s waters have just calmed enough for a daring vessel to set sail, whereas Cuba’s tides have churned into a tempest that swallows any ship daring to approach its horizon.
Lurline Wiese
Wow, the sanctions rollercoaster just gave me whiplash – one minute we’re cheering for Syrian growth, the next we’re watching Cuba get slammed.
Jenise Williams-Green
It is a moral imperative to condemn the selective leniency shown to Syria while the United States continues to enforce draconian measures against Cuba, perpetuating an unjust double standard that fuels global inequity.