Blocking Property of Certain Persons Contributing to the Situation in Burundi

This executive order declares a national emergency regarding the crisis in Burundi, blocking property of individuals and entities responsible for violence, human rights abuses, political repression, and threats to stability. It also suspends U.S. entry for sanctioned persons and prohibits financial transactions and donations benefiting them, with immediate effect.

Federal Register Open PDF 80 FR 73633

Impact dates

Nov 23, 2015
Order effective at 12:01 a.m. eastern standard time

Key directives

Block all property and interests in property of designated persons (Section 1)
Suspend immigrant and nonimmigrant entry of designated persons (Section 2)
Prohibit donations of specified articles to blocked persons (Section 3)
Prohibit contributions, provision of funds/goods/services to or from blocked persons (Section 4)
Prohibit evasion, avoidance, or conspiracy to violate order (Section 5)
Authorize Treasury to promulgate rules and regulations (Section 8)
Authorize Treasury/State to delist Annex persons (Section 9)
Authorize Treasury/State to submit recurring and final congressional reports (Section 10)

Who is ordered

Timeline

Immediate

Property blocking effective 12:01 a.m. EST November 23, 2015
Entry suspension takes effect
Listed Annex persons sanctioned

Near term (90d)

Treasury/State designation of additional sanctioned persons possible
Implementing regulations may be promulgated

Long term

Ongoing sanctions enforcement and compliance obligations
Potential delisting determinations under Section 9
Recurring congressional reports on national emergency

Risks & tensions

No prior notice requirement (Section 7) raises due process concerns for designated persons with constitutional presence in U.S.
Broad criteria for designation (Section 1(a)(ii)) creates uncertainty for humanitarian organizations regarding permissible activities
Potential tension between sanctions and humanitarian access given prohibition on support to persons blocking humanitarian assistance
Recurring congressional reporting obligation under NEA/IEEPA implies indefinite emergency duration unless terminated