ExecutiveOrdersEO
EO 13391Executive OrderG.W. Bush · R

Executive Order 13391

Blocking Property of Additional Persons Undermining Democratic Processes or Institutions in Zimbabwe

This executive order expands and replaces the sanctions regime against Zimbabwe by updating the annex of designated individuals and broadening criteria for blocking property of those who undermine democratic processes or institutions. It took effect immediately on November 23, 2005, and grants the Treasury Secretary authority to designate additional persons and issue implementing regulations.

Federal Register Open PDF 70 FR 71201

Impact dates

  1. Order takes effect; property blocking and prohibitions begin

Key directives

  • Replace and supersede Annex to EO 13288 with new Annex
  • Block all property and interests in property of designated persons
  • Prohibit donations to sanctioned persons under IEEPA section 203(b)(2)
  • Prohibit evasion, avoidance, and conspiracy to violate sanctions
  • Authorize Treasury Secretary to issue rules and regulations
  • Authorize Treasury Secretary to remove persons from sanctions list
  • Take effect at 12:01 a.m. EST November 23, 2005

Who is ordered

Timeline

Immediate

  • Property blocking takes effect at 12:01 a.m. EST November 23, 2005
  • All property of listed persons in U.S. jurisdiction frozen
  • Donations to sanctioned persons prohibited

Near term (90d)

  • Treasury Department may promulgate implementing rules and regulations
  • Potential additional designations by Treasury Secretary in consultation with State Secretary

Long term

  • Ongoing sanctions enforcement and compliance monitoring
  • Potential delisting determinations under Section 6 authority
  • Continuation of national emergency first declared in 2003

Risks & tensions

  • Vague 'undermine democratic processes' standard grants broad discretion to Treasury Secretary
  • Immediate family member designation (Sec. 1(a)(ii)(C)) raises potential due process concerns addressed through no-prior-notice finding
  • No sunset or review deadline specified; emergency authority continues indefinitely
  • Overlap with existing EO 13288 framework may create compliance complexity for financial institutions
Executive Order 13391: Blocking Property of Additional Persons Undermining Democratic Processes or Institutions in Zimbabwe · Executive Orders