Blocking Assets and Prohibiting Transactions With Significant Narcotics Traffickers

This executive order declares a national emergency to block assets and prohibit transactions with significant Colombian narcotics traffickers. It freezes all property and interests in property of designated foreign persons within U.S. jurisdiction and bars U.S. persons from any dealings with them.

Federal Register Open PDF 60 FR 54579

Impact dates

Date TBD
Secretary of Treasury to promulgate rules and regulations as necessary
Oct 22, 1995
Order effective at 12:01 a.m. EDT; asset blocking and transaction prohibitions take effect

Key directives

Block all property and interests in property of designated foreign narcotics traffickers (Section 1)
Prohibit any transaction or dealing by U.S. persons in blocked property (Section 2(a))
Prohibit evasion or attempted violation of sanctions (Section 2(b))
Authorize Secretary of Treasury to promulgate rules and regulations with AG and State consultation (Section 4)
Redelegation authority to other U.S. government officers and agencies (Section 4)

Who is ordered

Timeline

Immediate

Asset blocking effective 12:01 a.m. EDT October 22, 1995 for four named individuals in Annex
Prohibition on all transactions by U.S. persons with designated persons takes effect

Near term (90d)

Treasury to promulgate implementing rules and regulations
Potential designation of additional persons under criteria in sections 1(b) and 1(c)

Long term

Ongoing sanctions enforcement and compliance by U.S. financial institutions
Potential expansion of designated persons list
Enduring framework for narcotics-related sanctions authority

Risks & tensions

Vague timeline for regulatory implementation—no specific deadline for rulemaking
Risk of overbroad designation affecting innocent parties due to 'materially assist' and 'owned or controlled' criteria
Potential conflict with due process for designated persons lacking advance notice or hearing
Coordination required among Treasury, Justice, and State may slow enforcement
Definition of 'narcotics trafficking' is broad and could capture ancillary activities