On October 14, 2019, President Trump announced via Twitter his intention to authorize sanctions against Turkey and “any persons contributing to Turkey’s destabilizing actions in northeast Syria.” The announcement followed Turkey’s recent military operation against predominately Kurdish forces in northern Syria, which began following the withdrawal of U.S. troops from the region. Later in the day, President Trump issued an Executive Order (the “Syria-Turkey EO”) to formally implement those sanctions. Under the Syria-Turkey EO:

  • The U.S. Secretary of the Treasury is now authorized to impose blocking sanctions on any person that it determines to be: (i) responsible for or complicit in actions that threaten Syrian stability or abuse human rights, (ii) an official or agency of the Government of Turkey, or (iii) operating in sectors of the Turkish economy that the Secretary of Treasury might later decide to target with sanctions. The Syria-Turkey EO also authorizes the Treasury Secretary to impose blocking sanctions on any person (including non-U.S. persons) who provides material assistance, goods or services to or in support of any person sanctioned under the Syria-Turkey EO.
  • The U.S. Secretary of the Treasury is authorized to restrict or prohibit foreign financial institutions from opening or maintaining correspondent or payable through accounts in the U.S. if the Treasury Department determines that those foreign financial institutions have knowingly conducted or facilitated any significant financial transaction for or on behalf of any person who becomes subject to the above-described blocking sanctions.
  • The U.S. Secretary of State is now authorized to impose menu-based sanctions on any person the Secretary determines to have interfered with peacekeeping and restorative efforts in northern Syria. These authorized menu-based sanctions include (but are not limited to): blocking sanctions, denial of U.S. entry visas and financing-based sanctions.


Continue Reading President Trump Imposes Sanctions Against Turkey for its Syria Offensive

immigrationIn agreeing to review two rulings by the 4th Circuit Court of Appeals and 9th Circuit Court of Appeals on President Trump’s March 6, 2017, Executive Order, the Supreme Court reinstated certain provisions of the Executive Order that the lower courts had blocked. The March 6th Executive Order entitled “Protecting the Nation from Foreign Terrorist Entry into the United States” was to suspend visa issuance for individuals from six countries, including Libya, Iran, Somalia, Sudan, Syria, and Yemen for 90 days. This provision, often referred to as the “travel ban,” effectively prohibits travel to the United States for individuals from the six affected countries.

Continue Reading Supreme Court Allows Major Provisions of Travel Ban to Go Into Effect

globe AsiaOn Thursday, June 15, 2017, by a vote of 98-2, the U.S. Senate overwhelmingly passed a bill that would potentially impose additional sanctions against Russia and give Congress the power to delay and/or prevent any action by President Trump to lift or relax sanctions against Russia. Tentatively titled the “Countering Russian Influence in Europe and Eurasia Act of 2017” (“CRIEEA”), the bill must now proceed to the U.S. House of Representatives for further deliberation and approval.

Continue Reading Senate Passes Potential Russian Sanctions Bill

globeOn April 24, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a press release and updated the Specially Designated National (SDN) List by adding 271 new Syrian nationals that are employed by Scientific Studies and Research Center (SSRC).  SSRC is the Syrian government agency responsible for the development and deployment of Syrian dictator Bashar al-Assad’s chemical weapons program.  As a result of the designation, any assets held by the individuals in the United States will be frozen and U.S. persons are generally blocked from dealing with the listed individuals.

Continue Reading OFAC Adds 271 Syrian Individuals to the SDN List in Response to Sarin Gas Attack

New legislation, included as part of the government spending bill, enacts new changes to the visa waiver program (VWP), imposing additional restrictions on travelers from VWP countries.  The new changes require a consular interview for nationals of, or individuals who have traveled to, countries that have supported terrorism or other “high risk” countries, including Syria, Sudan, Iran, and Iraq, since March 2011.

Continue Reading Visa Waiver Program Changes Included in New Spending Bill