Blocking Property of Persons Undermining the Sovereignty of Lebanon or Its Democratic Processes and Institutions

This executive order declares a national emergency and authorizes the Treasury Secretary, in consultation with the Secretary of State, to block the property and interests of individuals and entities deemed to undermine Lebanon's sovereignty, democratic processes, or institutions, or to support Syrian interference in Lebanon. It prohibits transactions with designated persons and donations to them, with no prior notice required for listings.

Federal Register Open PDF 72 FR 43499

Impact dates

Date TBD
Recurring reports to Congress on national emergency per NEA section 401(c) and IEEPA section 204(c)

Key directives

Block all property and interests in property of designated persons in U.S. jurisdiction
Prohibit transfers, payments, exports, withdrawals, or other dealings with blocked property
Prohibit donations of articles specified in IEEPA section 203(b)(2) to designated persons
Prohibit contributions or provision of funds, goods, or services to or from designated persons
Prohibit evasion, avoidance, or conspiracy to violate order prohibitions
Treasury Secretary authorized to promulgate rules and regulations with State consultation
No prior notice required for listings of persons with constitutional presence in U.S.
All agencies directed to take appropriate measures to carry out provisions
Treasury Secretary authorized to submit recurring and final reports to Congress

Who is ordered

Timeline

Immediate

Blocking authority effective upon signing
All agencies directed to implement measures

Near term (90d)

Treasury/State promulgation of implementing regulations
Initial designations and listings of blocked persons

Long term

Ongoing sanctions enforcement and compliance
Recurring congressional reports on national emergency

Risks & tensions

Broad designation criteria ('significant risk of taking' actions) create wide discretionary authority for Treasury/State
No prior notice requirement for listings raises due process concerns despite constitutional presence finding
Spouse/dependent child blocking (sec. 1(a)(i)(C)) extends sanctions to family members without individualized determinations
Vague 'materially assisted' and 'goods or services' standards create compliance uncertainty for U.S. persons
Effectiveness depends on willingness to designate high-profile political actors in Lebanon and Syria