Blocking Property of Additional Persons in Connection With the National Emergency With Respect to Syria

This executive order expands sanctions related to the 2005 assassination of former Lebanese Prime Minister Rafiq Hariri by blocking U.S.-based assets of individuals and entities determined to be involved in that attack or related bombings in Lebanon, or who obstructed the UN investigation. It builds upon the existing national emergency declared in Executive Order 13338 concerning Syrian government actions.

Federal Register Open PDF 71 FR 25059

Impact dates

Apr 26, 2006
Order effective, asset blocking takes effect

Key directives

Block all property and interests in property of designated persons in U.S. or controlled by U.S. persons
Prohibit donations to designated persons under IEEPA section 203(b)(2)
Prohibit evasion, avoidance, or conspiracy to violate order
Authorize Treasury Secretary to issue rules and regulations after consulting State
Direct all agencies to take appropriate measures and advise Treasury

Who is ordered

Timeline

Immediate

Asset blocking effective April 26, 2006 at 12:01 a.m. EDT
Prohibitions on transfers, payments, exports, withdrawals apply
No prior notice required for designations

Near term (90d)

Secretary of Treasury to promulgate rules and regulations
Agencies to implement appropriate measures and advise Treasury

Long term

Ongoing designation of additional persons by Treasury in consultation with State
Potential expansion of sanctions based on investigation findings

Risks & tensions

No prior notice requirement (Section 4) raises due process concerns for designated persons with constitutional presence in U.S.
Vague standard for 'related to' Hariri assassination or 'implicating' Syria may lead to broad designation authority
Reliance on UN Commission findings that included allegations of false statements by senior Syrian official creates evidentiary chain dependency
Coordination required between Treasury and State on designations may slow or politicize implementation