Two OFAC rules from 25 September: Syria leaves the terrorism list rules, and penalties move to one part

OFAC published two rules on 25 September 2026, both effective the same day. Neither creates a new obligation for a bank or credit union. One reflects a real policy change on Syria; the other is a reorganization of where OFAC's penalty rules live. Both are the kind of thing that leaves stale citations in a sanctions procedure if nobody notices.

Syria and the Terrorism List Governments rules

The first rule (91 FR 60825) amends the Terrorism List Governments Sanctions Regulations, 31 CFR part 596. It removes and reserves § 596.505, a Syria-specific general license, because "the authorization is no longer necessary following the rescission" of Syria's designation as a State Sponsor of Terrorism.

The rule sets out the background. "Effective August 24, 2026, based on the considerations regarding Syria contained in the memorandum accompanying the Presidential Report of July 8, 2026, and in accordance with applicable law, the Secretary of State rescinded Syria's designation as a State Sponsor of Terrorism." That rescission was published at 91 FR 55965 on 31 August. The consequence for these regulations is stated plainly: "the Government of Syria is no longer a Terrorism List Government for purposes of the Regulations."

The rule says nothing about other Syria-related sanctions or restrictions. It deals only with part 596.

A single home for penalty rules

The second rule (91 FR 60821) adds a new 31 CFR part 505, the "Sanctions Penalties Regulations." It gathers penalty information for sanctions issued under the International Emergency Economic Powers Act (IEEPA) and the United Nations Participation Act. Penalties under some other statutes, including the Trading with the Enemy Act and the Clean Diamond Trade Act, stay in their existing sections.

OFAC is explicit that nothing changes in substance: "No substantive changes to these penalty provisions are being made with this rule." The new part restates, among other things, the IEEPA civil maximum of "up to the greater of $377,700 or twice the value of a transaction," and the existing practice that "Base penalties are halved in cases for which OFAC learns of the violation through a voluntary self-disclosure to OFAC."

Who it may reach

The Syria change matters to any institution whose sanctions procedures or screening rules treat Syria as a terrorism list country under part 596. The penalties rule reaches everyone who cites OFAC penalty provisions in training, board reporting or procedures, which is most sanctions programs.

What it could mean

Neither of these will change what your staff does on Monday morning. We'd still give each a few minutes, for different reasons.

On Syria, the risk is overcorrecting. Someone reads that Syria is no longer a Terrorism List Government and decides Syria-related payments can go through with less review. This rule doesn't support that. It speaks to part 596 and nothing else, and it doesn't touch the SDN list, other Syria programs or any designation of a Syrian person. Our view is that country risk ratings and geographic screening rules should change only after your BSA officer has checked every program that might apply, and that this is a good moment to ask whether your procedures say why Syria is on your high-risk list at all. If the only reason written down is the terrorism list, that reasoning is now out of date.

On penalties, the work is clerical. Training decks and sanctions procedures often quote the maximum civil penalty and the self-disclosure discount. The figures are the same; the citation may not be. If your materials point to penalty text in a program-specific part, check whether it now sits in part 505. Our guess is that OFAC will keep tidying in this direction, so it may be worth citing part 505 from now on.

The $377,700 figure is also a useful reminder for a board that hasn't heard about sanctions in a while. Twice the value of a transaction can be much larger than that on a single bad wire.