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On June 30, 2025, as part of the process of normalizing relations with Damascus following the overthrow of Syrian President Bashar al-Assad, the Trump administration overhauled the sanctions imposed on Syria to facilitate the rebuilding of that war-ravaged country. In the course of revising these sanctions, however, 266 employees of the Scientific Studies and Research Center, the heart of the Assad regime’s chemical weapons complex, were removed without explanation from the U.S. Department of the Treasury’s Specially Designated Nationals List. This list is a compilation of human rights abusers, proliferators, terrorists, drug lords, and others deemed a threat to U.S. national security. It is literally a list of the worst of the worst.
The 266 chemical weapons scientists, engineers, and technicians had been sanctioned by the first Trump administration in April 2017 in response to Syria’s sarin attack against Khan Sheikhoun, which killed more than 100 civilians. Trump’s treasury secretary at the time said, “The United States is sending a strong message with this action that we will hold the entire Assad regime accountable for these blatant human rights violations in order to deter the spread of these types of barbaric chemical weapons.” While sanctions reform to support the economic reconstruction and political stabilization of Syria is necessary, lifting these specific sanctions poses a proliferation risk, undermines accountability for the Assad regime’s chemical crimes, and weakens the global norm against chemical weapons.
The Trump administration should swiftly reinstate these sanctions.
Syria established the Scientific Studies and Research Center in the 1970s to develop advanced weapons, such as chemical weapons and ballistic missiles. Within the center, Institute 3000, with about 300 employees, was responsible for developing and producing chemical weapons, such as sulfur mustard and the nerve agents sarin and VX. The center also developed a range of chemical munitions, including aerial bombs, missile warheads, and short-range rockets. The United States first sanctioned the center for its role in Syria’s weapons of mass destruction programs in 2005.
Shortly following the start of the Syrian civil war, the Assad regime began using its chemical arsenal as a tool of repression against its own people. The regime conducted more than 340 chemical attacks that Syrian human rights groups estimate killed at least 1,500 people and injured 12,000 more. The sarin attack on Ghouta in Aug. 2013, which killed more than 1,000 civilians, was the single deadliest day of the civil war.
Under pressure from the United States and Russia, Syria signed the Chemical Weapons Convention and agreed to eliminate its chemical weapons program. In 2014, the Organization for the Prohibition of Chemical Weapons, the international organization charged with implementing the treaty, verified the destruction of Syria’s declared stockpile of chemical weapons, including the neutralization of sulfur mustard and sarin precursors onboard a converted U.S. cargo ship. Meanwhile, the Assad regime resumed the use of improvised chemical weapons loaded with chlorine against rebel-held areas.
The sarin attack on Khan Sheikhoun confirmed suspicions held by the United States, its allies, and the Organization for the Prohibition of Chemical Weapons that Syria had hidden some of its chemical arsenal after signing the Chemical Weapons Convention. The sarin used in this attack bore the unique to the formula developed by Syrian researchers, and the bombs were identical to those that Syria claimed to have already destroyed.
The Trump administration responded by striking the airbase where the attack had been launched from and imposing a record-setting round of sanctions on Syrian scientists, engineers, and technicians working on chemical weapons. At the time, Treasury stated, “These 271 [Scientific Studies and Research Center] employees have expertise in chemistry and related disciplines and/or have worked in support of [the Scientific Studies and Research Center]’s chemical weapons program since at least 2012.”
Based on a database compiled by the Biodefense Graduate Program at the Schar School of Policy and Government at George Mason University, the United States imposed sanctions on 306 individuals in Syria for activities related to the proliferation and/or use of chemical weapons between 2011 and 2025. The Syrian chemical weapons scientists sanctioned by Trump in 2017 constitute 88 percent of these individuals, and many were subsequently sanctioned by U.S. allies.
Among the eight executive orders, regulations, and statutes repealed by the Trump administration last June as part of the Syrian sanctions overhaul was the executive order used during Trump’s first term to sanction these chemical weapons experts. Although the new sanctions arrangement is designed to allow the continuation of sanctions against key figures in the Assad regime, as well as drug traffickers, terrorists, Iranian proxies, and proliferators, almost all of the chemical weapons researchers that had been sanctioned in 2017 were inexplicably removed from Treasury’s Specially Designated Nationals List.
Little is publicly known about most of these individuals, but they were viewed as a sufficient proliferation risk to warrant inclusion on the international watchlist maintained by the International Partnership Against Impunity for the Use of Chemical Weapons, a group of 25 countries committed to holding perpetrators of chemical attacks accountable and to upholding the international norm against chemical weapons. Members of the Partnership Against Impunity, including the United States, agreed to cooperate to identify those involved in the use of chemical weapons, to strengthen national and multilateral sanctions, and to share information for future prosecution of these perpetrators.
Of the 266 Syrian chemical weapons experts removed from the United States sanctions, additional information is available for two. Dr. Said Said was a “significant figure” who worked under the head of Institute 3000. He remains sanctioned by the European Union, by the United Kingdom, and is included in the French “vigilance list.” Dr. Hala Sirhan worked at Institute 3000 with Syria’s Military Intelligence Directorate which has been sanctioned by the United States and its allies for gross human rights violations, including the massacre of almost 300 unarmed civilians at Tadamon in April 2013 and the operation of a notorious prison system that tortured and killed thousands of Syrians during the civil war. Dr. Sirhan remains sanctioned by the European Union, the United Kingdom, and Australia. Both scientists remain on the Partnership Against Impunity’s sanctions watchlist.
While lifting some sanctions on the Syrian government, individuals, and entities is justified, it needs to be done strategically to avoid compromising nonproliferation goals.
There are concerns about how this move will affect efforts by the United States and its allies to hold accountable perpetrators of chemical attacks in Syria. The Specially Designated Nationals List is used by governments and countries around the world as a blacklist of individuals and entities with whom one should not do business. The removal of these chemical weapons developers from watchlists make it easier for them to conduct financial transactions, own international property, and travel, thereby increasing the proliferation risks that they pose.
The Trump administration has provided no public explanation for this delisting and neither State nor Treasury have been willing to provide an answer on the record. Therefore, we can only speculate as to why these Syrian chemical warfare scientists, engineers, and technicians were freed from U.S. sanctions. One possible explanation is that the United States views Syria’s chemical weapons program as a relic of the Assad era so the sanctions on these individuals were made redundant by the fall of the Assad regime. This doesn’t pass muster, however, since the United States has been calling for the new government in Damascus to cooperate with the Organization for the Prohibition of Chemical Weapons, resolve outstanding issues from the Assad era, and come into full compliance with the treaty banning chemical weapons. In addition, the new sanctions regime is also intended to be applied to Syrians involved in past proliferation activities. Indeed, the Trump administration has retained sanctions on 40 Syrian individuals for chemical weapons activities. Sixteen individuals with links to the chemical weapons program who were sanctioned under different executive orders have been moved to the new sanctions program and 19 individuals remain sanctioned under two authorities not impacted by the recent reform.
Another possibility is that the mass removal of Syrian chemical weapon experts from U.S. sanctions was the result of a rushed process as opposed to a well-thought policy decision. Trump’s announcement on May 13, 2025 that the United States would lift all sanctions on Syria, on the eve of his first meeting with Syrian President Ahmed al Sharaa, was a bold decision timed to have maximum political impact. This decision, however, caught U.S. sanctions officials by surprise. According to Reuters, “The White House had issued no memorandum or directive to State or Treasury sanctions officials to prepare for the unwinding and didn’t alert them that the president’s announcement was imminent … After the announcement, officials were confused about exactly how the administration would unwind the layers of sanctions, which ones were being eased and when the White House wanted to begin the process.” Nonetheless, despite this lack of preparation and the complexity of the multi-faceted sanctions that have been imposed on Syria since 1979, the White House issued its executive order overhauling these sanctions in just six weeks. At the same time that Treasury’s sanctions office was undertaking this major policy initiative, it was also undergoing a chaotic downsizing, was subject to a department-wide hiring freeze, and was grappling with the aftermath of a major cybersecurity breach.
Regardless of exactly how and why the decision to lift sanctions on 266 of Assad’s chemical weapons researchers was made, it was a mistake that can be easily fixed. The Trump administration can reinstate the sanctions immediately using existing authorities. This episode also highlights the need for the United States to better coordinate the overhaul of Syrian sanctions, including those related to chemical weapons, with its allies and partners. As more countries remove sanctions on Syria to facilitate reconstruction, they need to ensure that they don’t inadvertently lift sanctions on individuals who were responsible for the development or use of chemical weapons. A similar episode apparently occurred in 2023 when Australia lifted sanctions on 16 employees of the Scientific Studies and Research Center without a clear public explanation.
Lifting sanctions on scientists, engineers, and technicians who researched, developed, produced, and weaponized deadly chemicals and contributed to the worst chemical atrocities of the 21st century harms U.S. national security, undermines the pursuit of justice and accountability in Syria, and weakens the global norm against chemical weapons.
Gregory D. Koblentz is an associate professor and director of the biodefense graduate program at George Mason University’s Schar School of Policy and Government.
Rebecca Earnhardt is a Ph.D. candidate in the biodefense program at the Schar School.
Joel Keep is a research associate and Ph.D. candidate at the University of New South Wales in Sydney.
Image: U.S. Army via Wikimedia Commons
