President Obama Issues Executive Order Authorizing Targeted Sanctions on Persons in South Sudan
By Doug Jacobson and Michael Burton, Jacobson Burton PLLC
Today President Obama issued a new Executive Order ("EO") entitled “Blocking Property of Certain Persons With Respect to South Sudan.” The text of the EO can be found here.
Today’s EO does not actually name any persons in South Sudan or otherwise impose any restrictions on doing business with the Government of South Sudan or companies located in South Sudan.
This EO was issued in order to provide the U.S. government with a vehicle for imposing targeted sanctions on Government of South Sudan officials or opposition leaders that are responsible for the recent violence in South Sudan.
While OFAC will likely use this EO to add persons or government entities in Sudan to the List of Specially Designated Nationals and Blocked Persons ("SDN List"), no such parties have been added yet. Once those parties are added to the SDN List then any of their assets in the U.S. must be blocked and U.S. persons are prohibited from engaging in transactions with the SDNs. The EO also prohibits donations to the blocked persons.
South Sudan remains subject to normal export controls administered by BIS. Meanwhile, no changes have been made to the comprehensive U.S. sanctions on the Republic of Sudan (North Sudan).