OFAC doesn’t have an Overview of Sanctions document for this program, despite it being over 5 years old… so, we have to delve into Executive Order 13441, enacted August 3, 2007.
This is a targeted sanctions program – the Executive Order is entitled “Blocking
Property of Persons Undermining the Sovereignty of Lebanon or Its Democratic Processes and Institutions”.
So, the people subject to sanctions under this program are those determined to be:
(A) to have taken, or to pose a significant risk of taking, actions, including acts of violence, that have the purpose or effect of undermining Lebanon’s democratic processes or institutions, contributing to the breakdown of the rule of law in Lebanon, supporting the reassertion of Syrian control or otherwise contributing to Syrian interference in Lebanon, or infringing upon or undermining Lebanese sovereignty;
(B) to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, such actions, including acts of violence, or any person whose property and interests in property are blocked pursuant to this order;
(C) to be a spouse or dependent child of any person whose property and interests in property are blocked pursuant to this order; or
(D) to be owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to this order.
One thing I should mention, from looking at the E.O. – the Secretary of the Treasury makes the designations, but consults with the Secretary of State. So, since it’s financial crime, it falls under Treasury, but State is the one who knows who to sanction and who to hold off on (e.g. the Central Bank of Iran until recently).
Categories: Sanctions Programs