EO 13099Executive OrderClinton · D

Executive Order 13099

Prohibiting Transactions With Terrorists Who Threaten To Disrupt the Middle East Peace Process

This executive order amends Executive Order 12947 by adding Usama bin Ladin, Al-Qaida, and two associated individuals to the list of terrorists whose assets are blocked and with whom U.S. persons are prohibited from transacting. The order took effect immediately on August 21, 1998, following the August 7, 1998 U.S. embassy bombings in East Africa.

Impact dates

  1. Order effective at 12:01 a.m. eastern daylight time

Key directives

  • Revise Annex title to Executive Order 12947 to 'TERRORISTS WHO THREATEN TO DISRUPT THE MIDDLE EAST PEACE PROCESS'
  • Add Usama bin Ladin to sanctions list
  • Add Islamic Army/Al-Qaida to sanctions list
  • Add Abu Hafs al-Masri to sanctions list
  • Add Rifa'i Ahmad Taha Musa to sanctions list
  • Transmit order to Congress
  • Publish in Federal Register

Timeline

Immediate

  • Order effective 12:01 a.m. EDT August 21, 1998
  • Asset blocking and transaction prohibitions take effect against four newly listed persons/entities

Near term (90d)

  • Treasury/OFAC implementation of blocking requirements
  • Financial sector compliance adjustments

Long term

  • Precedent for expanding terrorism sanctions lists
  • Foundation for post-9/11 financial counterterrorism architecture

Risks & tensions

  • Jurisdictional tension: EO cites Middle East peace process as basis, but targets were primarily associated with East Africa attacks—geographic scope of 'national emergency' potentially stretched
  • Limited due process: No explicit procedural mechanism for challenging designation before effective date
  • Precedent for rapid expansion of sanctions lists without legislative action
  • Vague: 'Appropriate alphabetical order' leaves technical implementation to agency discretion
Executive Order 13099: Prohibiting Transactions With Terrorists Who Threaten To Disrupt the Middle East Peace Process · Executive Orders