Blocking Property of Certain Persons With Respect to Human Rights Abuses in Syria

This executive order expands a 2004 national emergency to block property of individuals and entities responsible for human rights abuses in Syria, particularly those involved in repressing peaceful protesters through violence, torture, and arbitrary detention. It authorizes the Treasury Secretary, in consultation with the Secretary of State, to designate additional persons and entities for sanctions, with immediate effect on April 29, 2011.

Federal Register Open PDF 76 FR 24787

Impact dates

Apr 29, 2011
Order effective at 1:00 p.m. EDT; property blocking takes effect

Key directives

Block all property of listed persons and those meeting designation criteria (Sec. 1)
Prohibit donations to blocked persons (Sec. 2)
Prohibit contributions, provision of funds/goods/services to or from blocked persons (Sec. 3)
Authorize Treasury Secretary to promulgate rules and regulations (Sec. 8)
Authorize Treasury Secretary to delist persons when circumstances warrant (Sec. 9)

Who is ordered

Timeline

Immediate

Property blocking takes effect at 1:00 p.m. EDT on April 29, 2011
Persons listed in Annex have assets frozen
Donations to blocked persons prohibited

Near term (90d)

Treasury/State designation of additional persons under criteria in Section 1(b)
Implementation of regulations and licensing framework

Long term

Ongoing sanctions enforcement and potential designations
Potential delisting determinations under Section 9
Continued freeze until emergency terminated or persons delisted

Risks & tensions

No prior notice required for listing (Sec. 7), raising due process concerns for U.S. persons affected
Broad 'materially assisted' standard in Sec. 1(b)(iii) creates compliance uncertainty for businesses
Reliance on prior emergency (EO 13338) without new congressional authorization
Vague 'human rights abuses' and 'repression' standards delegate significant interpretive authority to executive branch