ExecutiveOrdersEO
EO 13608Executive OrderObama · D Quiet signal

Executive Order 13608

Prohibiting Certain Transactions With and Suspending Entry Into the United States of Foreign Sanctions Evaders With Respect to Iran and Syria

This executive order authorizes the Treasury Secretary to block transactions with foreign individuals and entities that help Iran or Syria evade U.S. sanctions, and suspends their entry into the United States. It expands the U.S. sanctions enforcement toolkit by targeting 'foreign sanctions evaders' who previously may have fallen outside direct U.S. jurisdiction.

Federal Register Open PDF 77 FR 26409

Impact dates

  1. Treasury promulgation of rules and regulations to implement order

Key directives

  • Treasury Secretary authorized to impose transaction prohibitions on foreign sanctions evaders upon determination of criteria in Section 1(a)
  • Prohibition on all transactions or dealings involving designated persons, including exports, imports, financing, brokering, facilitating, or guaranteeing
  • Suspension of immigrant and nonimmigrant entry for persons meeting Section 1(a) criteria
  • Prohibition on evasion, avoidance, or conspiracy to violate order prohibitions
  • Treasury Secretary authorized to promulgate rules and regulations to carry out order purposes
  • No prior notice required for listings/determinations under Section 1

Who is ordered

Timeline

Immediate

  • EO effective upon signing; prohibitions apply immediately
  • no prior notice required before listing determinations
  • entry suspension takes effect immediately for designated persons

Near term (90d)

  • Treasury promulgation of implementing rules and regulations expected
  • agency coordination to establish enforcement mechanisms

Long term

  • ongoing sanctions enforcement and designations
  • potential expansion of sanctions evader lists
  • enduring restrictions on transactions and entry until lifted

Risks & tensions

  • No explicit deadline for regulatory implementation; timing left to Treasury discretion
  • Broad definition of 'deceptive transaction' and 'facilitating' creates enforcement uncertainty
  • No prior notice requirement raises due process concerns for designated persons
  • Potential conflict with allies whose nationals or companies may be designated
  • Section 11 explicitly limits Algiers Accords implications but signals awareness of legal sensitivity
Executive Order 13608: Prohibiting Certain Transactions With and Suspending Entry Into the United States of Foreign Sanctions Evaders With Respect to Iran and Syria · Executive Orders