Two New Sanctions Programs to Watch - Caesar and ICC

Caesar Act Sanctions

On June 17, 2020, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) sanctioned the first set of individuals and entities under the Caesar Syria Civilian Protection Act of 2019 (the Caesar Act).  Named for a Syrian photographer who documented torture in the regime of Syrian President Bashar al-Assad, the Caesar Act targets “foreign persons who facilitate the Assad regime’s acquisition of goods, services, or technologies that support the regime’s military activities as well as its aviation and oil and gas production industries.”

Five individuals and four companies were added to the Specially Designated Nationals and Blocked Persons List (SDN List), including two dual nationals of Syria and Canada.

Caesar Act sanctions are in addition to previously-existing Syria sanctions and Syria-related sanctions programs.

Executive Order Establishes ICC Sanctions

On June 11, 2020, the President issued Executive Order 13928, “Blocking Property of Certain Persons Associated with the International Criminal Court.”  This executive order is a response to assertions of jurisdiction over U.S. and allied personnel by the International Criminal Court (ICC), countries which are “are not parties to the Rome Statute or have not otherwise consented to ICC jurisdiction.”  This is the latest stage of a conflict that dates back the establishment of the ICC and 2002’s American Service-Members’ Protection Act.  The Secretary of State, in consultation with the Secretary of the Treasury and the Attorney General may sanction ICC personnel under this executive order, who would then be included on the SDN List and subject to a series of financial sanctions.  No individuals or entities have yet been sanctioned under this order.

Both of these developments serve as a reminder that denied party screening is needed to keep up with constantly changing sanctions lists and can apply to persons or entities in any country in the world.