ExecutiveOrdersEO
EO 13818Executive OrderTrump 45 · R Quiet signal

Executive Order 13818

Blocking the Property of Persons Involved in Serious Human Rights Abuse or Corruption

This executive order declares a national emergency to block the property of foreign persons involved in serious human rights abuse or corruption, building on the Global Magnitsky Human Rights Accountability Act. It authorizes the Treasury Secretary, in consultation with State and Justice, to designate individuals and entities for sanctions, bars their entry into the United States, and prohibits transactions with or for their benefit.

Federal Register Open PDF 82 FR 60839

Impact dates

  1. Order effective at 12:01 a.m. EST

Key directives

  • Block all property and interests in property of designated persons (Section 1(a))
  • Suspend immigrant and nonimmigrant entry of designated persons (Section 2)
  • Prohibit donations of IEEPA-specified articles to designated persons (Section 3)
  • Prohibit contributions, provision of funds/goods/services to or from designated persons (Section 4)
  • Prohibit evasion, avoidance, and conspiracy to violate order (Section 5)
  • Waive prior notice requirement for constitutional presence cases (Section 7)
  • Authorize Treasury to implement via regulations and redelegate (Section 8)
  • Authorize State to implement entry ban and reporting requirements (Section 9)
  • Authorize Treasury to delist Annex persons (Section 10)
  • Submit recurring and final reports to Congress (Section 11)

Who is ordered

Timeline

Immediate

  • Property blocking effective 12:01 a.m. EST December 21, 2017 for persons listed in Annex
  • Entry suspension takes effect immediately for designated persons
  • Donation prohibitions take effect

Near term (90d)

  • Treasury/State/Justice designation process for additional persons under criteria in Section 1(ii)-(iii)
  • Agency implementation measures under Sections 8-9

Long term

  • Ongoing sanctions designations and enforcement
  • Recurring congressional reports on national emergency
  • Potential delisting determinations under Section 10
  • Sustained impact on international anti-corruption and human rights accountability frameworks

Risks & tensions

  • Broad discretionary authority for Treasury/State/Justice designations creates due process concerns, compounded by Section 7's waiver of prior notice
  • Potential diplomatic friction with foreign governments whose officials are designated
  • Overlap with Global Magnitsky Act creates uncertainty about whether EO supplements or supersedes statutory framework
  • Vague 'complicit in' and 'indirectly engaged in' standards may chill legitimate transactions
  • No explicit criteria or process for delisting beyond Treasury discretion
Executive Order 13818: Blocking the Property of Persons Involved in Serious Human Rights Abuse or Corruption · Executive Orders