Enab Baladi – Mohammad Kakhi
Following the fall of the Syrian regime, organizations specializing in asset recovery, and their experts, moved quickly to launch initiatives urging the Syrian authorities to begin tracing assets and wealth hidden by the Assad family and its close circle.
According to a report published by the French newspaper Intelligence, some organizations and asset-recovery specialists hope to secure a mandate from the new Syrian government to pursue lucrative recovery deals, similar to efforts to recoup the assets of Saddam Hussein in Iraq and Muammar Gaddafi in Libya.
Since the outbreak of the Syrian uprising in 2011, many countries have used asset freezes to pressure the ousted president, Bashar al-Assad. Countries such as Switzerland, the United States, and the United Kingdom froze assets owned by the Syrian state as well as by the deposed president and his family.
Enab Baladi asked specialized organizations and contacted legal and economic experts to understand the mechanisms and laws for recovering Syrian assets held abroad, and what the new Syrian government and civil society should do in this context.
Assad’s hidden wealth
From Damascus palaces to offshore accounts
A 2022 US State Department report estimated the Assad family’s net overseas wealth at between one and two billion dollars. It said the assets are part of a complex network spanning tangible holdings (real estate in Dubai, Moscow, and London), jewelry, income-generating assets (such as boutique hotels in Vienna), and vehicles (luxury cars and a private jet).
The Department noted that the estimate is imprecise and could not be independently verified.
Manuel Perrino, Regional Advisor for the Middle East and North Africa at Transparency International, told Enab Baladi that determining the location and size of the Assad family’s assets, and those of their partners, is extremely complex.
He said the family’s total assets are far greater than one or two billion euros. He pointed to an accumulation of gold bars estimated at more than 200 tons, adding that the State Department’s dollar estimate could be multiplied up to ten times, or even by 60. Some estimates place the family’s holdings around 22 billion dollars, while others suggest that, when aggregated, Assad’s assets could reach 122 billion dollars, according to Perrino.
Bundles of Syrian banknotes as an employee counts money at the Central Bank of Syria – December 16, 2024 (Reuters)
Distinguishing sovereign assets from elite wealth
Asset-tracing experts differentiate between elites’ private wealth and sovereign assets because the tools to track and recover them differ. Private assets owned by ruling elites pose a major challenge for organizations and states seeking to trace or freeze them due to the elaborate methods used to conceal ownership.
Legal researcher and international law consultant Mohammed Harbaliyah told Enab Baladi that asset freezes are imposed either by the UN Security Council against individuals, groups, or states through a Council resolution, or unilaterally by a state against individuals, entities, or other states for reasons including threats to international peace and security, support for terrorism, or human-rights violations. Freezes may target both officials’ finances and state assets.
Perrino explained that the bulk of the Assad family’s assets were likely spread across various personal accounts, though some of their private wealth was also held at the Central Bank of Syria.
Jackson Oldfield, Director of Research and Policy at the Civil Forum for Asset Recovery (CIFAR), said sovereign assets are those directly attributable to the state itself, such as government accounts or state-owned stakes abroad. Private wealth held overseas remains private unless courts establish that it is the proceeds of corruption, either through criminal or civil proceedings.
Oldfield told Enab Baladi that unfreezing government assets is much simpler than unfreezing private money. The former is typically a political decision or a straightforward judicial procedure. By contrast, assets owned by individuals or companies require lengthy judicial steps, potentially in Syria and in the jurisdiction where the assets are held, or at least in one of them, to prove they are proceeds of corruption, culminating in a final, non-appealable judgment.
On 12 March, the European Parliament approved a draft resolution enabling the use of frozen assets belonging to the ousted Assad regime in EU countries to support Syria’s political transition and reconstruction. The Parliament urged the EU and member states to back Syria’s transitional authorities and called on Damascus to end its historic alliances with Tehran and Moscow.
On 23 May, the US Treasury’s Office of Foreign Assets Control (OFAC) announced exemptions easing some Syria-related sanctions, provided the exemptions do not benefit Iran or Russia. According to international law consultant Mohammed Harbaliyah, this does not constitute a full lifting of freezes but rather a conditional, monitored easing.
On 22 May, Syria’s finance minister stated that funds frozen abroad are not large, but that they belong to the Syrian people and will be used according to the country’s economic priorities.
Perrino said the Central Bank appears to be seeking the return of its own frozen assets abroad separately from Assad’s private wealth because sovereign assets can be recovered faster and through simpler procedures in the short term.
Paradoxically, he added, when the Central Bank’s assets were frozen under sanctions, the Assad family’s private holdings were not, since they were owned through front companies, straw persons, and other strategies.
An employee at an exchange office in Damascus – April 16, 2025 (AFP/Louai Beshara)
With little transparency and limited international trust
A complex legal race to recover funds
Experts agree that pursuing elite assets believed to have been amassed through corruption is complex and requires sustained cooperation among organizations and states.
Perrino said Syrian authorities must gather evidence proving that these assets were obtained through corruption and trace where they currently are. This need not be a purely Syrian effort; Damascus can work with countries where assets are believed to be located.
He added that Syria should coordinate with counterparts in those countries to design the best strategies for confiscating corruption proceeds and returning them, and to understand the legal steps, evidentiary standards, and admissibility criteria required by foreign courts.
Zaki Mehchi, a researcher at the London School of Economics and Political Science, told Enab Baladi that neither sovereign assets nor elite wealth can be recovered easily. Much depends on transparency policies at the Central Bank of Syria. Governments will not transfer money to an institution whose transparency is in doubt. In Iraq, for example, Saddam Hussein’s funds were not returned directly; an international fund was established to support Iraq, and money was channeled to that fund due to mistrust in Iraqi financial institutions.
In Syria’s case, the United Nations could form a body or working group under its supervision to recover Syria’s frozen assets on behalf of the Syrian people. This would require substantial institutional and legal effort, Mehchi said.
According to Perrino, any state committed to recovering stolen assets should invest in strong, independent, non-partisan institutions, such as dedicated units within the central bank, and the ministries of finance, justice, and foreign affairs, ensuring continuity, training, resources, and international networks so momentum is not lost during political transitions.
Legally, he added, there are tools to facilitate recovery, including civil forfeiture (a legal mechanism to recover assets or money obtained unlawfully without requiring a criminal conviction), mutual legal assistance (MLA) treaties, and memoranda of understanding with other states.
Réka Furtos, Communications Officer at the UN Office on Drugs and Crime (UNODC), told Enab Baladi that Syria previously signed the UN Convention against Corruption (UNCAC), which obliges signatories to use all available means to trace, seize, freeze, confiscate, and return assets acquired through corruption. But Syria has not ratified the convention and therefore does not currently participate in its Implementation Review Mechanism.
Oldfield explained that Syria can request assistance to pursue these assets. Ideally, Syrian authorities should contact counterparts in jurisdictions where assets are thought to be located and request their help.
If Syria ratifies UNCAC, the process would become easier, he said, since asset recovery relies heavily on cooperation. The more Syria engages in cooperation mechanisms, the greater its chances of securing official partners and streamlining the process.
Key actors involved in tracing and identifying elites’ assets:
StAR (the joint World Bank–UNODC Stolen Asset Recovery initiative)
The REPO Task Force (focusing on sanctioned Russian elites, proxies, and oligarchs), a coalition of G7 countries, the EU, and Australia to identify, freeze, and confiscate targeted assets
The US Treasury’s Office of Foreign Assets Control (OFAC)
The UK’s Office of Financial Sanctions Implementation (OFSI)
Source: Civil Forum for Asset Recovery (CIFAR)
International law consultant Mohammed Harbaliyah said tracing and recovering funds requires specialized legal and financial teams capable of uncovering shell companies and secret accounts and following the money trails of the Assad family.
The Syrian government can also sign cooperation agreements with countries likely to be used by Assad to hide wealth under aliases or through proxies.
Mohammed Yosr Bernieh, Minister of Finance, attends the World Bank Spring Meetings in Washington – April 2025 (Yosr Bernieh/LinkedIn)
How Assad Hid His Wealth
A 2022 US State Department report stated that the Assad family managed to circumvent financial systems by using aliases or relying on other individuals to obscure ownership and evade sanctions. According to NGO and media reports, the family runs a sophisticated patronage network involving shell companies, corporate fronts that provide apparent legitimacy, and even non-profit organizations, all of which enable access to financial resources and laundering of proceeds from illicit economic activities.
International law researcher and consultant Mohammed Harbaliyah told Enab Baladi that offshore companies, legal entities registered in one country to conduct business in another, and jurisdictions allowing secret accounts without disclosing true ownership, gave the Assad family tools to conceal their wealth, making it difficult to trace assets.
Jackson Oldfield, Director of Research and Policy at the Civil Forum for Asset Recovery (CIFAR), said the challenge with Assad’s assets lies in donor countries’ concerns that Syrian institutions might not be able to safeguard returned funds from being stolen again, which could nullify recovery efforts. Negotiations are therefore expected between donor governments and Syria’s authorities on channeling these funds into specific development projects or managing them through the United Nations or other mechanisms.
Transparency International advisor Manuel Perrino stressed that once assets are returned, the main questions will be: Who manages the funds? Who decides how they are used? And who oversees accrued interest while the money is deposited? Such issues are handled through international or regional agreements guiding the roles of institutions like the Syrian Central Bank and the Syrian Financial Intelligence Unit (FIU, established in 2007 to track suspicious assets).
Syria’s Ministry of Finance did not respond to Enab Baladi’s inquiry about activating the FIU within the Central Bank or the Ministry of Finance to systematically pursue frozen assets.
Zaki Mehchy, researcher at the London School of Economics and Political Science, told Enab Baladi that tracing Assad’s wealth presents a dilemma for governments and organizations because of the wide range of mechanisms he used to complicate freezing measures and weaken their effectiveness. In addition to tax havens and offshore structures, Assad benefited from allied states like Russia and the UAE, investing in property, land, and financial assets beyond the reach of seizure.
Mehchy added that Assad also used digital currencies as an additional escape route, since such technology allows anonymity and the transfer of funds beyond oversight. Asset freezes are only possible when holdings are directly tied to an individual’s name in countries with clear legislation, such as Switzerland, which has specific laws for freezing dictators’ funds. In places like the UAE or Russia, the lack of a legal or political framework makes recovery nearly impossible.
He noted that obstacles multiply when it comes to funds held by Assad’s relatives or associates, as it requires judicial proof that the wealth is looted rather than private. This is particularly difficult because efforts were made to give the money a veneer of legitimacy through seemingly legal economic fronts.
A torn image of Bashar al-Assad inside his presidential palace after the regime’s fall and the opposition’s entry – December 8, 2024 (AP)
International legal framework for asset recovery:
UNCAC: UN Convention against Corruption (signed by Syria but not ratified)
OECD Anti-Bribery Convention: Syria is not a member
Mutual Legal Assistance Treaties (MLATs): Syria is not a member
Arab Anti-Corruption Convention: Syria is a party as an Arab League member
(Source: Transparency International)
Role of civil society
Transparency International is currently organizing training in Iraq, Lebanon, and Tunisia on Beneficial Ownership Transparency (BOT) and advocacy.
Perrino said involving Syrian civil society organizations (CSOs) in tracing and recovering assets remains challenging due to Syria’s highly volatile context. Transparency International will only cooperate with independent, non-partisan groups whose members are not placed at risk.
He added that preliminary trainings on BOT, designed to reveal the true owner of companies or accounts hidden under aliases or shell entities, could be conducted if Syrian CSOs can travel to neutral countries. Such activities would also depend on donor funding from entities like the EU or Germany’s GIZ.
Harbaliyah explained that international and local organizations cannot directly claim frozen assets because they lack the legal authority to represent the Syrian people. However, they can play an important role in advocating for the Syrian government’s legitimacy in demanding the return of these funds.
What if states refuse to release funds?
In 2023, the United States refused to return Iran’s frozen assets despite an International Court of Justice (ICJ) ruling ordering compensation to Iranian companies for unlawfully frozen assets. Washington withheld the bulk of the funds, $1.75 billion from the Iranian Central Bank, arguing they were reserved for compensating victims of Iran-linked attacks.
Although the ICJ acknowledged that the US violated aspects of the 1955 Treaty of Amity, it exempted the Central Bank’s assets and declined to compel Washington to return them.
Harbaliyah told Enab Baladi that if a state’s assets are frozen by another country in violation of an international treaty, it may file a case at the ICJ, as Iran did in 2023. Alternatively, it can pursue litigation in national courts where the assets are held. However, since freezing is usually based on domestic legislation, national courts often cannot overturn such measures because they are legally grounded.
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