As part of its escalating pressure on Syria to cease its crackdown on recent demonstrations, the United States government has imposed a new round of sanctions targeting the Syrian President, Bashar al-Assad, and some of his top aides. These sanctions follow those issued in April under Executive Order 13572, which targeted Syria’s intelligence agency and two relatives of President Assad for alleged human rights abuses.
The new Executive Order, “Blocking Property of Senior Officials of the Government of Syria” (the “EO”), blocks the property and interests in property of President Assad and the country’s vice president, prime minister, interior minister, defense minister, head of military intelligence, and director of political security forces. As such, the EO prohibits U.S. persons from engaging in any transaction or dealing which involves the property or interests in property of these officials, including the making or receiving of “any contribution of funds, goods, or services by, to, or for the benefit of any [designated party].” In conjunction with the EO, the Treasury Department’s Office of Foreign Assets Control has added President Assad and these other top officials to its Specially Designated Nationals and Blocked Persons List.
Further, the EO also authorizes the Secretary of the Treasury, in consultation with the Secretary of State, to block the property and interests in property of agencies or instrumentalities “of the Government of Syria” or “owned or controlled, directly or indirectly, by the Government of Syria or by an official or officials of the Government of Syria." The designation of such entities would prevent their property interests from being “transferred, paid, exported, withdrawn, or otherwise dealt in” by U.S. persons. This could have profound ramifications on trade-related transactions with Syria, as many of the country’s industries are state-controlled, particularly in the energy sector. However, the EO stops short of imposing the level of sanctions as those currently imposed on Libya under Executive Order 13566, which by its terms automatically blocks all property and interests in property of the Government of Libya (see “International Trade Update: Imposition of Broad New U.S. Sanctions Targeting the Government of Libya,” March 4, 2011).