Today, the United States Department of Treasury Office of Foreign Assets Control (“OFAC”), has added a new part to the Code of Federal Regulations. This part, found at 31 C.F.R. Part 543, implements Executive Order 13396, “Blocking Property of Certain Persons Contributing to the Conflict in Cote d’Ivoire.”

The Cote d’Ivoire Sanctions Regulations blocks transactions with persons identified in the Annex to 13396, as well as persons identified as constituting a threat to the national reconciliation process in Cote d’Ivoire, individuals responsible for serious violations of international law in Cote d’Ivoire, persons having supplied materials or assistance to military activities in Cote d’Ivoire, individuals who have publicly incited violence and hatred in the conflict in Cote d’Ivoire, or who have materially assisted individuals who have been designated under these regulations.

Penalties for violations of these regulations are found in section 206 of the International Emergency Economic Powers Act (“IEEPA”). As always individuals who have reason to believe they may be in violation should seek out counsel to ensure their compliance with the regulations.

The addition of this new part is good in that it provides guidance to those individuals and entities that might run afoul of Executive Order 13396. As has been stated previously in this blog, OFAC administered sanctions regulations can be complex and difficult to navigate. Thus, these regulations finally provide some insight in to how U.S. persons can comply with Executive Order 13396. The only complaint this author can lodge is that its implementation comes some 3 years after the Executive Order was issued. That just seems far too long of a period for individuals and entities to be denied guidance on how to comply with these U.S. sanctions laws. While it may take some time to draft the actual regulations, OFAC may want to consider issuing some sort of interim regulations, while the final CFR Part is being drafted. This would help individuals and entities comply with the sanctions which in turn would promote OFAC’s purpose in administering these programs.

For more information about the Cote d’Ivoire Sanctions Regulations click here.