News from Reeves & Dola, LLP
Today’s alert is from guest author Susan Heidenreich, a seasoned professional with over 20 years’ experience in investigations and implementation of economic/trade sanctions supporting U.S. national security and economic strategy architecture. Many of you may have seen her recent posts on LinkedIn linkedin.com/in/Susan-Hedenreich-MBA on issues related to U.S. sanctions and foreign policy matters. We are proud to give her the floor to share her insights into recent developments and to increase awareness about the sanctions delisting process.
Sanctions as Instruments of Behavior Modification, Not Punishment
Sanctions are often misunderstood as purely punitive — an effort to isolate or economically weaken a state or entity until it yields to international pressure. But in reality, sanctions are not designed to punish; they are meant to influence behavior and shape decision-making through non-military means.
At their core, sanctions are a form of diplomacy — a financial signal that enforces norms, deters illicit activity, and incentivizes lawful conduct. When the behavior that prompted sanctions changes, or when policy objectives evolve, those same tools must be flexible enough to support reintegration and reform.
This balance — between enforcement and engagement — is what gives sanctions their credibility as instruments of responsible statecraft.
The Syria Case: From Isolation to Conditional Reintegration
On May 13, 2025, President Trump first announced the lifting of sanctions on Syria to give the country a chance at peace and prosperity. This was followed by Executive Order 14312, which formally terminated, as of July 1, 2025, the broad economic sanctions on Syria, ending one of the longest-running sanctions programs in the region. Under this new framework, U.S.-origin food, medicine, and humanitarian goods may be exported without specific OFAC licenses — marking a shift from economic isolation to managed engagement. In addition, more than 500 individuals and entities were delisted from OFAC’s Specially Designated Nationals List, including the Central Bank of Syria. OFAC repealed the Syrian Sanctions Regulations (31 CFR Part 542) and the U.S. Department of Commerce eased certain export restrictions while maintaining safeguards on dual-use and security-sensitive goods. For more information, please refer to the Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria.
This recalibration reflects a deliberate shift in U.S. policy — one that recognizes evolving regional realities and seeks to balance accountability with reintegration. The lifting of comprehensive sanctions also reopens doors for humanitarian organizations, reconstruction financing, and development partnerships — but with those opportunities comes heightened responsibility.
Sanctions as Dialogue
The changes in U.S. and Syria relations underscores an often-overlooked truth: finance is a language of diplomacy. Every sanction designation — and every removal — tells a story about accountability, evolution, and the balance between pressure and partnership. Sanctions are not static barriers; they are dynamic instruments of negotiation. When behavior changes, they can become bridges back into the international system.
Viewed through this lens, sanctions are not merely punitive — they are corrective mechanisms that, when responsibly applied, can drive progress, rebuild trust, and support peace through accountability.
Inside the Delisting Process — Where Policy Meets Compliance
A sanction designation does not have to be permanent, and removal from the U.S. Government’s sanctions lists is possible. The process for requesting removal from sanctioned status includes submission of a written removal request (a “petition” or “request for reconsideration”) to the appropriate agency. The request should provide a detailed description of why you are requesting removal and include supporting evidence to show why there is an insufficient basis for the listing or that the circumstances resulting in the listing no longer apply. Legal representation is not required to seek removal from a sanctioned designation, but it is recommended as the process is highly technical and nuanced and can involve evidence or information of a sensitive and possibly classified nature.
From the U.S. Government’s perspective, key decision points include:
- Behavioral Review: Verifying that the sanctioned party has ceased prohibited activity or met policy benchmarks.
- Risk Assessment: Ensuring removal will not compromise counterterrorism or nonproliferation goals.
- Diplomatic Validation: Confirming that the decision aligns with U.S. and allied strategic objectives.
Delisting is neither symbolic nor spontaneous — it’s the outcome of a rigorous interagency process involving the Departments of Treasury, State, Commerce, Justice, and Defense. Each case is assessed against evolving intelligence, legal criteria, and strategic policy priorities.
About the Guest Author
Susan’s career highlights include numerous deployments to the Middle East, Southwest Asia, and South America, targeting and disrupting terrorist networks, narcotics and arms traffickers, human trafficking and smuggling operations, and investigating and designating transnational criminal organizations and public corruption worldwide. Susan’s service and support to USG includes the U.S. Special Operations Command and Departments of the Treasury, Justice, and State. Susan was instrumental in the U.S. Government’s establishment of Iraq’s Financial Intelligence Unit and guiding and mentoring Iraqi investigators in the pursuit and reclamation of nearly 1 billion dollars of stolen Iraqi sovereign wealth during the global war on terror.
Susan holds advanced degrees in finance and international business development and is the founder of FCG consultancy and Financial Diplomacy, through which she continues her support and service to the U.S. law enforcement and intelligence communities. She can be reached at Sheidenreich@friggacg.com.
About Reeves & Dola
Reeves & Dola is a Washington, DC law firm that specializes in helping clients navigate the highly regulated and complex world of manufacturing, sales and international trade of defense and commercial products. We have a deep understanding of the Federal regulatory process, and use our expertise in working with a variety of Federal agencies to assist our clients with their transactional and regulatory needs. Learn more at https://reevesdola.com/. Join their mailing list and stay informed of industry news.
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