CRS Report Details Broad Language in Executive Order on Iraq

In July we brought attention to Executive Order 13, 438 which authorizes the government to seize the assets of "any person" who threatens the stability of Iraq and any person who provides assistance to such a person. The lack of clear standards to define what criteria will be used to determine when an entity poses a significant risk or what constitutes a threat to the peace or security of the Iraqi government leaves charities operating in Iraq vulnerable. Now a newly released Congressional Research Service (CRS) report highlights the broad nature of the Executive Order. The issue is whether the executive order's application to anyone who provides "support" for a designated entity might affect U.S. persons inadvertently involved in some form of assistance, such as arranging transportation for, selling consumer goods to, or providing routine legal assistance to an entity which becomes blocked under the executive order. Could such U.S. persons find themselves designated under the authority of the executive order and thereby have all of their assets subject to blocking whether or not the assets have any nexus with the transaction with the blocked entity or with any foreign entity? Read this blog at Secrecy News with the appropriate title, "Executive Order on Asset Seizure Casts a Wide Net."
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