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EO 13582Executive OrderObama · D Quiet signal

Executive Order 13582

Blocking Property of the Government of Syria and Prohibiting Certain Transactions With Respect to Syria

This executive order blocks all property of the Syrian government and its controlled entities within U.S. jurisdiction, prohibits new U.S. investment in Syria, bans exports of services to Syria, prohibits imports of Syrian petroleum and petroleum products, and bars U.S. persons from dealing in Syrian oil. It also authorizes the Treasury Secretary to designate additional individuals and entities for sanctions.

Federal Register Open PDF 76 FR 52209

Impact dates

  1. Order effective - all prohibitions and blocking provisions take effect

Key directives

  • Block all Syrian government property and interests in property in U.S. jurisdiction (Section 1(a))
  • Authorize Treasury Secretary to designate additional persons for blocking (Section 1(b))
  • Prohibit new U.S. investment in Syria (Section 2(a))
  • Prohibit exportation or supply of services to Syria by U.S. persons (Section 2(b))
  • Prohibit importation of Syrian petroleum and petroleum products (Section 2(c))
  • Prohibit U.S. persons from dealing in Syrian petroleum products (Section 2(d))
  • Prohibit facilitation of foreign person transactions that would be prohibited for U.S. persons (Section 2(e))
  • Prohibit donations to blocked persons (Section 3)
  • Prohibit contributions, provision of funds/goods/services to or from blocked persons (Section 4)
  • Treasury Secretary authorized to issue rules and regulations (Section 10)
  • All agencies directed to implement order (Section 10)

Who is ordered

Timeline

Immediate

  • All Syrian government property blocked as of 12:01 a.m. EDT August 18, 2011
  • Prohibitions on new investment, services exports, petroleum imports, and petroleum dealings take effect
  • No prior notice required for designations

Near term (90d)

  • Treasury Secretary to promulgate implementing rules and regulations
  • Potential designation of additional persons under Section 1(b)

Long term

  • Ongoing sanctions enforcement and compliance monitoring
  • Potential expansion of designated persons network
  • Structural impact on U.S.-Syria economic relations

Risks & tensions

  • Broad 'material assistance' standard in Section 1(b)(i) creates compliance uncertainty for businesses
  • Extraterritorial application to U.S. persons 'wherever located' raises international jurisdictional tensions
  • Petroleum sanctions may affect global oil markets and allied energy interests
  • No prior notice requirement (Section 9) limits due process protections
  • Facilitation prohibition (Section 2(e)) could complicate foreign bank dealings with Syria
  • Vague 'technological support' language in Section 1(b)(i) may capture unintended activities
Executive Order 13582: Blocking Property of the Government of Syria and Prohibiting Certain Transactions With Respect to Syria · Executive Orders