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Council Implementing Regulation (EU) 2025/1094 of 27 May 2025 implementing Regulation (EU) No 36/2012 concerning restrictive measures in view of the situation in Syria

Type Implementing Regulation
Publication 2025-05-28
State In force
Text As published
Department Council of the European Union
Source EUR-Lex
articles 2

This is the act as published. Later amendments are not folded into the text below: each one is a separate act in this repository and an entry in this law's history.

Reform history JSON API
Name Identifying information Reasons Date of listing
‘1. Bena Properties Cham Holding Building, Daraa Highway, Ashrafiyat Sahnaya Rif Dimashq, Syria, P.O. Box 9525 Held by Rami Makhlouf. Syria’s largest real estate company and the real estate and investment arm of Cham Holding; provides funding to the former al-Assad regime. 23.6.2011
2. Al Mashreq Investment Fund (AMIF) (a.k.a. Sunduq Al Mashrek Al Istithmari) P.O. Box 108, Damascus, Syria; Tel: +963 112110059 / 963 112110043; Fax: +963 933333149 Held by Rami Makhlouf; provides funding to the former al-Assad regime. 23.6.2011
3. Hamcho International (a.k.a. Hamsho International Group) Baghdad Street, P.O. Box 8254, Damascus, Syria; Tel: +963 112316675; Fax: +963 112318875; Website: www.hamshointl.com; E-mail: info@hamshointl.com and hamshogroup@yahoo.com Hamcho International is a large Syrian holding company owned by Mohammed Hamcho. Hamcho International benefits from and provides support to the former al-Assad regime and is associated with a person benefiting from and supporting the former al-Assad regime. 27.1.2015
4. Military Housing Establishment (a.k.a. MILIHOUSE) Public works company controlled by Riyad Shalish and Ministry of Defence; provides funding to the former al-Assad regime. 23.6.2011
5. Political Security Directorate Syrian government agency directly involved in repression under the former al-Assad regime. 23.8.2011
6. General Intelligence Directorate Syrian government agency directly involved in repression under the former al-Assad regime. 23.8.2011
7. Military Intelligence Directorate Syrian government agency directly involved in repression under the former al-Assad regime. 23.8.2011
8. Air Force Intelligence Agency Syrian government agency directly involved in repression under the former al-Assad regime. 23.8.2011
9. IRGC Qods Force (a.k.a. Quds Force) Teheran, Iran The Qods (or Quds) Force is a specialist arm of the Iranian Islamic Revolutionary Guard Corps (IRGC). The Qods Force is involved in providing equipment and support to help the former al-Assad regime suppress protests in Syria. The Qods Force has provided technical assistance, equipment and support to the Syrian security services to repress civilian protest movements. 23.8.2011
10. Mada Transport Subsidiary of Cham Holding (Sehanya Dara’a Highway, P.O. Box 9525); Tel: +963 11 99 62 Economic entity financing the former al-Assad regime. 2.9.2011
11. Cham Investment Group Subsidiary of Cham Holding (Sehanya Dara’a Highway, P.O. Box 9525); Tel: +963 11 99 62 Economic entity financing the former al-Assad regime. 2.9.2011
13. Addounia TV (a.k.a. Dounia TV) Tel: +963 11 5667274; +963 11 5667271; Fax: +963 11 5667272; Website: http://www.addounia.tv; Relatives/business associates/entities or partners/links: SAMA TV (sister company); website: www.sama-tv.net Addounia TV has incited violence against the civilian population in Syria under the former al-Assad regime. 23.9.2011
14. Cham Holding Cham Holding Building - Daraa Highway – Ashrafiyat Sahnaya Rif Dimashq – Syria PO Box 9525; Tel: +963 11 9962; +963 11 668 14000; +963 11 673 1044; Fax: +963 11 673 1274; Email: info@chamholding.sy; Website: www.chamholding.sy Controlled by Rami Makhlouf; second-largest holding company in Syria, benefiting from and supporting the former al-Assad regime. 23.9.2011
15. El-Tel. Co. (El-Tel. Middle East Company) (a.k.a. Abraj Tech) Dair Ali Jordan Highway, P.O. Box 13052, Damascus, Syria; Tel: +963 11 2212345; Fax: +963 11 44694450; Email: sales@eltelme.com; Company owner: Maher Dsouki; Websites: www.eltelme.com, www.abrajtec.com Manufacturing and supplying communication and transmission towers and other equipment for the Syrian army under the former al-Assad regime. 23.9.2011
16. Ramak Constructions Co. Dara’a Highway, Damascus, Syria; Tel: +963 11 6858111; Mobile: +963 933 240231 Construction of military barracks, border post barracks and other buildings for army needs under the former al-Assad regime. 23.9.2011
21. Centre d’études et de recherches syrien (CERS) (a.k.a. Centre d’Etude et de Recherche Scientifique (CERS); Scientific Studies and Research Centre (SSRC); Centre de Recherche de Kaboun) Barzeh Street, P.O. Box 4470, Damascus, Syria Provides support to the Syrian army under the former al-Assad regime for the acquisition of equipment used for the surveillance and repression of demonstrators under the former al-Assad regime. Operating in the chemical weapons proliferation sector, it is the government entity responsible for developing and producing non-conventional weapons, including chemical weapons, and the missiles to deliver them. 1.12.2011
42. Ministry of Defence Umayyad Square, Damascus, Syria Tel: +963 11 7770700 Syrian government branch directly involved in repression under the former al-Assad regime. 26.6.2012
43. Ministry of Interior Merjeh Square, Damascus, Syria Tel: +963 11 2219400; +963 11 2219401; +963 11 2220220; +963 11 2210404 Syrian government branch directly involved in repression under the former al-Assad regime. 26.6.2012
44. Syrian National Security Bureau Syrian government branch and element of the Syrian Ba’ath Party. Directly involved in repression under the former al-Assad regime. It directed Syrian security forces to use extreme force against demonstrators. 26.6.2012
48. Drex Technologies S.A. Incorporation date: 4.7.2000; Incorporation number: 394678; Director: Rami Makhlouf; Registered agent: Mossack Fonseca & Co (BVI) Ltd Drex Technologies is wholly owned by Rami Makhlouf, who is listed under Union sanctions for providing financial support to the former al-Assad regime. Rami Makhlouf uses Drex Technologies to facilitate and manage his international financial holdings, including a majority share in SyriaTel, which the Union has previously listed on the grounds that it also provides financial support to the former al-Assad regime. 24.7.2012
52. Megatrade Aleppo Street, P.O. Box 5966, Damascus, Syria; Fax: +963 11 4471081 Acts as a proxy for the Scientific Studies and Research Centre (SSRC), which is listed. Involved in trade in dual use goods prohibited by Union sanctions for the former al-Assad government. 16.10.2012
53. Expert Partners Rukn Addin, Saladin Street, Building 5, P.O. Box 7006, Damascus, Syria Acts as a proxy for the Scientific Studies and Research Centre (SSRC), which is listed. Involved in trade in dual use goods prohibited by Union sanctions for the former al-Assad government. 16.10.2012
58. Army Supply Bureau P.O. Box 3361, Damascus, Syria Involved in the procurement of military equipment for the former al-Assad regime, and therefore responsible for the violent repression of the civilian population in Syria. Branch of the Syrian Ministry of Defence. 23.7.2014
59. Industrial Establishment of Defence (a.k.a. Industrial Establishment of Defense (IED); Industrial Establishment for Defence; Defence Factories Establishment; Establissements Industriels de la Defense (EID); Establissement Industrial de la Defence (ETINDE), Coefficient Defense Foundation) Al Thawraa Street, P.O. Box 2330 Damascus, Syria Or Al-Hameh, Damascus Countryside, P.O. Box 2230, Syria Involved in the procurement of military equipment for the former al-Assad regime, and therefore responsible for the violent repression of the civilian population in Syria. Branch of the Syrian Ministry of Defence. 23.7.2014
60. Higher Institute for Applied Sciences and Technology (HIAST) (Image omitted; see official source Image omitted; see official source) (a.k.a. Institut Supérieur des Sciences Appliquées et de Technologie (ISSAT)) P.O. Box 31983, Barzeh, Syria Affiliated to and a subsidiary of the Syrian Scientific Studies and Research Centre (SSRC) which is already designated by the Council. It provides training and support to the SSRC and is therefore responsible for the violent repression of the civilian population under the former al-Assad regime. 23.7.2014
61. National Standards & Calibration Laboratory (NSCL) P.O. Box 4470, Damascus, Syria Affiliated to and a subsidiary of the Syrian Scientific Studies and Research Centre (SSRC) which is already designated by the Council. It provides training and support to the SSRC and is therefore responsible for the violent repression of the civilian population under the former al-Assad regime. 23.7.2014
65. Organisation for Technological Industries (OTI) (a.k.a. Technical Industries Corporation (TIC)) P.O. Box 11037, Damascus, Syria Subsidiary of the Syrian Ministry of Defence, which has been designated by the Council. OTI is involved in the production of chemical weapons for the former al-Assad regime. It is therefore responsible for the violent repression of the Syrian population. As a subsidiary of the Ministry of Defence, it is also associated with a designated entity. 7.3.2015
67. Hamsho Trading (a.k.a. Hamsho Group; Hmisho Trading Group; Hmisho Economic Group) Hamsho Building, 31 Baghdad Street, Damascus, Syria Hamsho group, Damascus countryside – northern road-ring, Hamsho for trading and constructions; Email: info@hamsho-group.com; Tel: 00963 (11) 3227530 Subsidiary of Hamsho International, which has been designated by the Council. As such, Hamsho Trading is associated with a designated entity, Hamsho International. Supports the former al-Assad regime through its subsidiaries, including Syria Steel. Through its subsidiaries it is associated with groups such as the former al-Assad-regime affiliated Shabiha militias. 7.3.2015
72. Rawafed Damascus Private Joint Stock Company (a.k.a. Rawafed/Rawafid/Rawafed (Tributary)Image omitted; see official sourceDamascus Private Joint Stock Company) Damascus, Syria A USD 48,3  million joint venture between Damascus Cham Holding, Ramak Development and Humanitarian Projects, Al-Ammar LLC, Timeet Trading LLC (a.k.a. Ultimate Trading Co. Ltd.) and Wings Private JSC. Rawafed supports and/or benefits from the former al-Assad regime, including through its participation in the luxury development Marota City. 21.1.2019
73. Aman Damascus Joint Stock Company (a.k.a. Aman Damascus JSC) Damascus, Syria A USD 18,9  million joint venture between Damascus Cham Holding and Aman Group. Through its participation in the former al-Assad regime-backed luxury development Marota City, Aman Damascus supports and/or benefits from the former al-Assad regime. 21.1.2019
74. Bunyan Damascus Private Joint Stock Company (a.k.a. Bunyan Damascus Private JSC) Damascus, Syria A USD 34,8  million joint venture between Damascus Cham Holding and Apex Development and Projects LLC and Tamayoz LLC. Through its participation in the former al-Assad regime-backed luxury development Marota City, Bunyan Damascus Private Joint Stock Company supports and/or benefits from the former al-Assad regime. 21.1.2019
75. Mirza Damascus, Syria A USD 52,7  million joint venture between Damascus Cham Holding and Talas Group. Through its participation in the luxury development Marota City backed by the former al-Assad regime, Mirza supports and/or benefits from the former al-Assad regime. 21.1.2019
77. Al Qatarji Company (a.k.a. Qatarji International Group; Al-Sham and Al-Darwish Company; Qatirji/Khatirji/Katarji/Katerji Group) (مجموعة/شركة قاطرجي) Type of entity: private company; Business sector: import/export; trucking; supply of oil and commodities; Name of Director/Management: Hussam Al Qatarji, CEO (designated by the Council); Ultimate beneficial owner: Hussam Al Qatarji (designated by the Council); Registered address: Mazzah, Damascus, Syria; Relatives/business associates/entities or partners/links: Arvada/Arfada Petroleum Company JSC Prominent company operating across multiple sectors of the Syrian economy. By facilitating fuel, arms and ammunition trade between the former al-Assad regime and various actors including ISIL (Da’esh) under the pretext of importing and exporting food items, supporting militias fighting alongside the former al-Assad regime and taking advantage of its ties with the former al-Assad regime to expand its commercial activity, Al Qatarji Company – whose board is headed by designated person Hussam Al Qatarji, a member of the Syrian People’s Assembly – supports and benefits from the former al-Assad regime. 17.2.2020
78. Damascus Cham Holding Company (a.k.a. Damascus Cham Private Joint Stock Company (القابضة الشام دمشق) Type of entity: public-owned company under private law; Business sector: real estate development; Name of Director/Management: Adel Anwar al-Olabi, Chairman of the Board of Directors and Governor of Damascus (designated by the Council); Ultimate beneficial owner: Governorate of Damascus; Relatives/business associates/entities or partners/links: Rami Makhlouf (designated by the Council); Samer Foz (designated by the Council); Mazen Tarazi (designated by the Council); Talas Group, owned by businessman Anas Talas (designated by the Council); Khaled al-Zubaidi (designated by the Council). Damascus Cham Holding Company was established by the former al-Assad regime as the investment arm of the Governorate of Damascus in order to manage the properties of the Governorate of Damascus and implement the Marota City project, a luxurious real estate project based on expropriated land under Decree No 66 and Law No 10 in particular. By managing the implementation of Marota City, Damascus Cham Holding (whose Chairman is the Governor of Damascus) supports and benefits from the former al-Assad regime and provides benefits to businesspeople with close ties to the former al-Assad regime who have struck lucrative deals with this entity through public-private partnerships. 17.2.2020
79. Velada LLC OOO Велада Address: Ochakovskoye Shosse, Dom 28, Building 2, Local 3, Room 8, Moscow, 119530, Russian Federation; Date of creation: 29.6. 2015 Velada LLC is a private company that is involved in the oil and gas sector in Syria. In December 2019, the Syrian parliament approved a contract granting Velada LLC the right to develop oil and gas in Syria, including in oilfields in the regime-controlled areas in Northeast Syria and a gas field north of Damascus. Thus, it benefits from or supports the former al-Assad regime. 13.12.2021
80. Mercury LLC OOO Меркурий Address: Leninsky Prospekt, Dom 137, Building 1, Local 2, Room 5, Moscow, Russian Federation Mercury LLC is a private company involved in the oil and gas sector in Syria. In December 2019, the Syrian parliament approved a contract granting Mercury LLC the right to develop oil and gas in Syria, including in oilfields in the regime-controlled areas in Northeast Syria and a gas field in the north of Damascus. Thus, it benefits from or supports the former al-Assad regime. 13.12.2021
81. Evro Polis LLC OOO Евро Полис Address: Ulitsa Bratev, Gozozankinykh, Dom 2B, Pomeshchenie 3.1., Krasnogorsk, 143409, Russian Federation; Relatives/Associates: General Petroleum Corp. Evro Polis LLC is a private company linked to the Wagner Group in Syria, involved in the mining, oil and gas sectors in Syria. Evro Polis LLC is used as a front for the Wagner Group in Syria. It has signed a number of contracts with the former al-Assad regime, through the state-owned General Petroleum Corp., under which it receives 25 % of the proceeds from the production of oil and gas in fields captured by the Wagner Group. Thus, it benefits from or supports the former al-Assad regime. 13.12.2021
82. Sanad Protection and Security Services (شركة سند للحرسات والخدمات الأمنية) Type of entity: Limited Liability Company Date of creation: 22 October 2017 Headquarters: Damascus Sanad Protection and Security Services is a Syrian private security company, established in 2017 and supervised by the Wagner Group in Syria, active in the protection of Russian interests (phosphates, gas and securing oil sites) in Syria. The exploitation of natural resources provides revenues to the former al-Assad regime. In addition, the company is active in the recruitment of Syrian mercenaries to Libya and Ukraine. As such, the company supports the former al-Assad regime and benefits from it. 21.7.2022
83. Fourth Armoured Division of the Syrian Army الفرقة الرابع Place of registration: Damascus; Principal place of business: Syrian regime territory in Syria; Associated individuals: Maher al-Assad, Ghassan Belal The Fourth Armoured Division is one of the most prominent military units of the Syrian army during the former al-Assad regime led by Maher al-Assad and commanded by Ghassan Bilal. The Fourth Armoured Division is responsible for the violent repression of the civilian population. The Fourth Armoured Division also profits form the war economy, especially the trafficking in Captagon. Captagon trade has become a business model led by the former al-Assad regime, enriching the inner circle of the former al-Assad regime and forming its lifeline. Therefore, the Fourth Armoured Division benefits from and supports the former al-Assad regime. 24.4.2023
84. Neptunus LLC/Neptune LLC company شركة نبتونوس المحدودة المسؤولية نبتونس أوفرسيز المحدودة Place of registration: Lattakia, Syria; Date of registration: 2017 Neptunus LLC is involved in drug operations in the port of Latakia. Neptunus LLC therefore benefits from and supports the former al-Assad regime. Neptunus LLC was co-founded by Taher Al-Kayali. 24.4.2023
85. Areen foundation/مؤسسة العرين Place of registration: Syria; Date of registration: 1999; Principal place of business: Syria; Associated individuals: Asma al-Assad (wife of Bashar al-Assad and Director) The al-Areen foundation poses as a charitable foundation, but is closely affiliated with former al-Assad regime-affiliated militias. The al-Areen foundation is directed by the former President’s wife, Asma al-Assad. The foundation is channelling aid in line with the policies and priorities of the former al-Assad regime, and therefore benefits from and supports the former al-Assad regime. 24.4.2023
86. Stroytransgaz/Стройтрансгаз Other information: Stroytransgaz Group, Stroytransgaz (STG) Logistic, Stroytransgaz (STG) Engineering, STG Engineering Stroytransgaz is a Russian engineering and construction company operating in Syria, which amongst other things assumed control of Syria’s largest phosphate mines. Stroytransgaz therefore benefits from and supports the former al-Assad regime. 24.4.2023
87. Gecopham, the General Company for Phosphate and Mines الشركة العامة للفوسفات و المناجم Address: Palmyra Road, Homs, Syrian Arabic Republic; Phone: 00963312751122; Email: info@gecopham.sy; General Manager: Younes Ramadan Gecopham is controlled by the Syrian Ministry of Petroleum and Mineral Resources and provides financial support to the former al-Assad regime. It therefore supports the former al-Assad regime. 24.4.2023
88. Al-Jabal Security and Protection LLC شركة الجبل لخدمات الحماية والحراسة Address: F6XR+495, Malek Bin Rabeaa, Damascus, Syria; Type of entity: Limited Liability Company; Place of registration: Damascus; Date of registration: 19.10.2017; Principal place of business: Damascus, Syria; Associated individuals: Osama Mohammad al-Maliki Al-Jabal Security and Protection LLC is owned and managed by Osama al-Maliki. Al-Jabal Security and Protection LLC acts as a shell company to allow for the continuation of activities of the Saraya al-Areen 313 militia, a regime-affiliated militia. Al-Jabal Security and Protection LLC therefore benefits from and supports the former al-Assad regime. 24.4.2023
89. Castle for Security and Protection LLC شركة القلعة للحماية والحراسة والخدمات الأمني a.k.a. Castle Security and Protection LLC, Citadel for Security and Protection Address: Saraya Roundabout, Western Villas, Mazze, Damascus, Syria; Type of entity: Limited Liability Company; Place of registration: Damascus, Syria; Date of registration: 18.10.2017; Principal place of business: Damascus, Syria; Other information: Sector: Militia turned Security Company; Phone Number: +963116119331; +963943800808 Castle for Security and Protection LLC is a private company, which acts as a shell company for the Fourth Division of the Syrian Arab Army, which is led by Maher al-Assad. Castle for Security is involved also in the trafficking of narcotics. The Captagon trade has become a business model led by the former al-Assad regime, enriching the inner circle of the former al-Assad regime and forming its lifeline. It therefore benefits from and supports the former al-Assad regime. 24.4.2023
90. Aman for Protection and Security LLC شركة أمان للحماية والحراسة الأمنية Address: Damascus Countryside; Type of entity: Limited Liability Company; Place of registration: Damascus Countryside; Date of registration: 10.10.2018; Registration number: 2906; Principal place of business: Damascus Countryside, Syria; Associated individuals: Muhammad Abdo Assad Aman for Protection and Security LLC is a private security company, which acts as a shell company for the Hosn al-Watan milita, founded by Muhammad Abdo Assaad. It therefore benefits from and supports the former al-Assad regime. 24.4.2023
91. Al-Dj Group (a.k.a. ALDJ) Place of registration: Damascus, Syria; Principal place of business: Syria Al-Dj Group is a Syrian business entity, owned and managed by Mahmoud al-Dj. As a holding company it owns and operates the Freebird Travel Agency, an agent for Cham Wings Airlines, which is conducting frequent flights between Syria and Libya, smuggling mercenaries, and narcotics. Al-Dj Group is further associated with Al-Tair Company, which is also owned by Mahmoud al-Dj. Through this scheme of business relations, in which Al-Dj Group plays a central role, cargo shipping and flights are used for illicit transactions between regime-affiliated persons and entities in Syria and Eastern Libya, including narcotics. Al-Dj Group’s activities benefit the former al-Assad regime and support it in accessing illicit revenues. 22.1.2024
92. Cham Wings Place of registration: Damascus, Syria; Principal place of business: Damascus, Syria Cham Wings Airlines is a Syrian business entity which is owned by Muhammad Issam Shammout. Also, Cham Wings uses its flights to engage in the transfer of Syrian mercenaries, arms trade, narcotics trafficking, and money laundering, which supports the activities of the former al-Assad regime. As the only private airline in Syria, Cham Wings is therefore benefiting from, and providing support to the former al-Assad regime. 22.1.2024
93. Freebird Travel Agency Place of registration: Syria, Dubai; Principal place of business: Damascus, Syria The Freebird Travel Agency is a Syrian business entity owned and operated by Al-Dj Group, which in turn is owned and managed by Mahmoud al-Dj. Freebird serves as principal agent for Cham Wings Airlines, and thereby benefits from and provides support to the former al-Assad regime. 22.1.2024
94. Iloma Investment Private JSC (a.k.a. Eloma) Place of registration: Damascus, Syria; Date of registration: 2023; Principal place of business: Damascus, Syria Iloma Investment Private JSC has been established at the beginning of 2023 to take over almost half of the ownership of Damascus airport. Iloma is a front for the Assad family and part of the former al-Assad regime’s efforts to personally gain from manipulation of the economy. Therefore, Iloma is supporting and benefiting from the former al-Assad regime. 22.1.2024’.

ELI: http://data.europa.eu/eli/reg_impl/2025/1094/oj

ISSN 1977-0677 (electronic edition)

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