Blocking Property of Senior Officials of the Government of Syria

This executive order freezes all U.S.-based assets of senior Syrian government officials and entities, prohibiting any transactions with them. It expands existing sanctions against Syria in response to escalating violence against protesters and repression of democratic change.

Federal Register Open PDF 76 FR 29143

Impact dates

May 18, 2011
Order effective at 1:00 p.m. eastern daylight time

Key directives

Block all property and interests in property of listed persons and designated senior Syrian officials
Prohibit donations of articles specified in IEEPA section 203(b)(2)
Prohibit contributions or provision of funds, goods, or services to or from blocked persons
Authorize Treasury Secretary to promulgate rules and regulations
Authorize Treasury Secretary to determine delisting of Annex persons
Direct all U.S. government agencies to take appropriate measures to carry out order

Who is ordered

Timeline

Immediate

Asset blocking effective at 1:00 p.m. EDT on May 18, 2011
No prior notice required for listings
Prohibitions on transfers, payments, exports, withdrawals

Near term (90d)

Treasury/State Department designations of additional persons under Section 1(b)
Potential promulgation of implementing regulations

Long term

Ongoing sanctions enforcement and compliance
Potential delisting determinations under Section 9
Integration with broader Syria sanctions regime

Risks & tensions

No prior notice requirement (Section 7) raises due process concerns for designated persons
Broad delegation to Treasury Secretary with State consultation creates interagency dynamics
Vague 'senior official' standard in Section 1(b)(i) leaves designation discretion wide
Annex persons not visible in provided text—scope of immediate impact unclear