Blocking Property of Certain Persons Contributing to the Conflict in Somalia

This executive order declares a national emergency and blocks U.S.-based property of individuals and entities contributing to conflict, piracy, or instability in Somalia. It authorizes Treasury and State to designate persons who threaten Somali peace processes, obstruct humanitarian aid, violate the UN arms embargo, or support such activities. The order takes effect immediately and applies to both listed individuals and future designations.

Federal Register Open PDF 75 FR 19869

Impact dates

Apr 13, 2010
Order effective at 12:01 a.m. eastern daylight time

Key directives

Block all property of designated persons in U.S. jurisdiction (Section 1(a))
Prohibit donations of articles specified in IEEPA section 203(b)(2) (Section 1(c))
Prohibit evasion, avoidance, or conspiracy to violate order (Section 2)
Authorize Treasury to promulgate rules and regulations (Section 5)
Authorize Treasury to submit recurring and final reports to Congress (Section 6)
Authorize Treasury to delist Annex persons when circumstances warrant (Section 7)

Who is ordered

Timeline

Immediate

Property blocking effective 12:01 a.m. EDT April 13, 2010
Annex-listed persons' assets frozen
Prohibitions on transactions and donations take effect

Near term (90d)

Treasury/State designation of additional persons under criteria in Section 1(a)(ii)
Implementation of regulations and licensing framework

Long term

Ongoing sanctions enforcement and designations
Periodic congressional reporting on national emergency
Potential delisting determinations under Section 7

Risks & tensions

No prior notice requirement (Section 4) raises due process concerns for designated persons
Vague criteria in 1(a)(ii)(A) 'threaten peace, security, or stability' grants broad discretion to Treasury/State
Potential tension with humanitarian operations if aid delivery is inadvertently affected by sanctions
No explicit sunset or review period; emergency declaration persists indefinitely
Overlap with existing UN sanctions regime may create compliance complexity for international actors