[email protected]
Wed, Jul 3, 2024 at 10:38 PM
To: [email protected]
Cc: [email protected], [email protected], [email protected]
Hello,
Thank you for your email. In general, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) does not administer comprehensive sanctions against the West Bank. The West Bank is not subject to broad, jurisdiction-based sanctions at this time, meaning that not all activity involving the West Bank, or persons located in the West Bank, are necessarily prohibited.
OFAC administers and enforces an economic sanctions program targeting individuals and entities associated with the West Bank, as set forth in the West Bank-Related Sanctions (the Regulations), Executive Order 14115, issued under the authority of the International Emergency Economic Powers Act, 50 U.S.C. §§ 1701-06 and other statutes. The Regulations generally prohibit all...
1) Background
The OFAC Compliance Hotline guidance requests that are the subject of this item are not, in and of themselves, particularly illuminating as it relates to OFAC’s law and practice, but the guidance read in light of the incoming requests and subsequent federal court complaint are notable for reasons described further below.
On February 1, 2024 (all dates referenced below 2024 unless otherwise specified), President Biden issued EO 14115, which contains a number of designation criteria related to the West Bank, including engaging in actions “directing, enacting, implementing, enforcing, or failing to enforce policies — that threaten the peace, security, or stability of the West Bank”. The designation criteria are limited to “foreign persons” (a term undefined in the EO).
Concurrent with the issuance of the EO, the State Department designated certain Israeli individuals,...