EU General Court Upholds EU Syria Sanctions on Samer Al Dibs (T‑405/24)
On 18 March 2026, the General Court (Fifth Chamber) rejected in full the action brought by Syrian businessman Samer Al Dibs in Case T-405/24, confirming the legality of his 2024 and 2025 relistings under the EU’s Syria sanctions regime and ordering him to pay costs.
Mr Al Dibs sought annulment (insofar as they concern him) of:
• 2024 relisting: Decision (CFSP) 2024/1510 of 27 May 2024 and Implementing Regulation (EU) 2024/1517 of 27 May 2024
• 2025 relisting: Implementing Decision (CFSP) 2025/1095 of 27 May 2025 and Implementing Regulation (EU) 2025/1094 of 27 May 2025. These acts are based on Decision 2013/255/CFSP and Regulation (EU) No 36/2012 concerning Syria.
Initially listed in April 2023 (Decision 2023/847; Regulation 2023/844), Mr Al Dibs is described as:
• An influential businessman operating in Syria, active notably in chemicals and real estate
• A member of the Syrian–Chinese Business Council
• President of the Damascus & Rural Damascus Chamber of Industry
• A member of the Syrian Parliament
• A close associate of Maher Al Assad, benefiting from and supporting the regime
Since 2015, the EU Syria regime includes an autonomous ground for listing “influential businessmen operating in Syria”, which creates a rebuttable presumption of a link to the Assad regime once influence and economic activity in Syria are established.
The Court’s Key Findings
2024 Relisting (Pre Assad Fall)
• The Council relied on evidence from 2021–2023, including media and company records, showing Mr Al Dibs as a prominent investor appearing alongside Bashar Al Assad and holding significant positions in Syrian industry and politics.
• The Court held that this evidence was recent, concrete and consistent, and sufficient to qualify him as an influential businessman in Syria.
• Mr Al Dibs tried to rebut the presumption by citing residence in Lebanon and health issues, supported by a residence certificate and medical report. The Court found these insufficient: residence abroad is not enough to sever links, and the medical evidence did not show inability to conduct business.
• The fall of the Assad regime (8 December 2024) could not affect the legality of the 2024 acts, which must be assessed as of 27 May 2024.
2025 Relisting (Post Assad Fall)
Following Assad’s fall, the Council amended the regime via Decision 2025/1096 and Regulation 2025/1098 to target:
• Persons benefitting from/supporting the former regime
• Members of the Assad/Makhlouf families and linked persons
• Influential businessmen operating in Syria “linked to the former Assad regime”
For 2025, the Council provided updated evidence (WK 4875/2025 REV 1), including:
• Reporting on Assad-linked business networks remaining powerful and difficult to dismantle
• Articles naming Mr Al Dibs as part of Assad’s business circle who relocated to Lebanon after the regime’s fall
• Material on ex regime figures abroad (including in Lebanon) allegedly financing violence in Syria
The Court found that:
• The Council had done an updated assessment of both the Syrian context and Mr Al Dibs’s role.
• He remained an influential businessman linked to the former regime, and he had not produced new evidence capable of breaking the presumption.
Takeaways
• The judgment confirms the strength and flexibility of the Syria sanctions framework, including after regime change.
• The “influential businessman” criterion remains a powerful tool: once applied, the burden shifts to the listed person to produce solid, specific evidence that links and influence have genuinely ended.
• Open source material (media, corporate records) continues to be accepted as a sufficient evidential basis where the applicant offers no substantial rebuttal.
• For listed business figures, successful delisting will require detailed, documented evidence of divestment, loss of influence, and disengagement from former regime networks.