Executive Order 13536 [Executive Order Blocking Property of Certain Persons Contributing to the Conflict In Somalia]

Date issued: Apr. 12 2010

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TURBOFAC Commentary (630 words)

Notes Common to Executive Order 13536 and Executive Order 13620

The prohibitions of EO 13536 and EO 13620 are, as of 4/28/2021, fully incorporated in the Somalian Sanctions Regulations (SoSR), which were reissued and amended on 4/28/2021. From 2010 through 2021, the SoSR took the form of an “abbreviated” set of sanctions regulations which did not take account of EO 13620. Prior to 4/28/2021, Executive Order 13536 was Appendix A to part 551.

Sec. 1 of EO 13620 amends the designation criteria and basic blocking prohibition contained in EO 13536. With respect to those designation criteria, they are fairly regular, with certain “primary” designation criteria not of interest to the typical legitimate commercial actor, along with the standard “derivative designation” criteria, i.e. “materially assisting” blocked persons, acting on behalf of blocked persons and being owned or controlled by blocked...