ExecutiveOrdersEO
EO 13338Executive OrderG.W. Bush · R Quiet signal

Executive Order 13338

Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria

This executive order declares a national emergency and imposes sanctions on Syria, blocking property of individuals and entities supporting Syrian government activities including terrorism, occupation of Lebanon, WMD programs, and undermining Iraq stabilization. It prohibits export of munitions, most commerce-controlled items, and other U.S. products to Syria, with limited exceptions for food and medicine, and restricts Syrian-owned air carrier operations in U.S. airspace.

Federal Register Open PDF 69 FR 26751

Impact dates

  1. EO effective date - all prohibitions take effect

Key directives

  • Secretary of State shall prohibit export/reexport of Munitions List items to Syria
  • Secretary of Commerce shall prohibit export/reexport of Commerce Control List items to Syria
  • Secretary of Commerce shall prohibit export/reexport of non-CCL U.S. products except food and medicine
  • Secretary of Transportation shall prohibit Syrian-owned air carriers from scheduled services and most takeoffs/landings
  • Secretary of Treasury shall block property of designated persons contributing to Syrian government prohibited activities
  • Secretary of State authorized to exercise SAA waiver functions
  • All agencies directed to implement and advise on measures

Who is ordered

Timeline

Immediate

  • Export prohibitions take effect at 12:01 EDT May 12, 2004
  • Property blocking authority becomes active
  • Syrian air carrier restrictions implemented

Near term (90d)

  • Secretaries to promulgate implementing rules and regulations
  • Department of Commerce General Order No. 2 implementation

Long term

  • Ongoing sanctions enforcement and designation of blocked persons
  • Recurring congressional reports on national emergency
  • Potential adjustments via licenses and waivers

Risks & tensions

  • Waiver provisions (Sections 7-8) create tension between sanctions pressure and diplomatic flexibility
  • No prior notice for property blocking (Section 11) raises due process concerns for U.S.-present individuals
  • Broad delegation to agency secretaries with redelegation authority may create inconsistent implementation
  • Humanitarian carve-out for food/medicine requires careful regulatory boundary-drawing
  • Syria-Lebanon occupation nexus became moot after 2005 Syrian withdrawal, though WMD and terrorism designations remained active
Executive Order 13338: Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria · Executive Orders