Executive Order 13818: Sanctions against persons

What The Executive Order Says

Executive Order (EO) 13818 is entitled "Blocking the Property of Persons Involved in Serious Human Rights Abuse or Corruption" and was issued December 20th, 2017 and it was continued a year later in December 2018.  It has 13 sections, a preamble and an annex.  The annex lists 13 specific persons to whom the sanctions listed in the EO apply.  The preamble declares a national emergency due to the threat imposed by human rights abuses and corruption around the world that threaten the national security, foreign policy and economy of the US.

Section 1

This section decrees that a freeze be implemented on the financial assets of persons named in the Annex.  Also anyone in the US who conducts business with the names persons will end up with their assets frozen.  Despite the freeze, there may be exemptions due to statutes and regulations and current contracts can be fulfilled.

Section 2

This section suspends the ability of the names persons to enter into the United States, whether for immigration or non-immigration purposes.  Then it refers to an old Proclamation (no. 8693) as to how to apply the rules.  In review, it is noted that use of that Proclamation seems formulaic or else it is really well written.

Section 3

This Section prohibits donations in lieu of commercial transactions.

Section 4

This section expands on the prohibitions in section 1.  These specific items are intended to emphasize that doing business with the named persons is illegal.

Section 5

This section prohibits transactions or conspired transactions which would circumvent the prohibitions defined in this EO.

Section 6

This section defines the terms "person", "entity" and "United States person"

Section 7

This section provides justification for not including a notice period.

Section 8

This section delegates to the Secretary of the Treasury to take whatever steps are allowed by the Statute and are necessary to implement the Executive Order.  The Secretary can then request other federal agencies to take actions to implement the Executive Order.

Section 9

This section delegates to the Secretary of State the necessary authority to carry out the actions specified in section 2 of this EO.

Section 10

This section delegates the authority to end the blocking of property to the Secretary of the Treasury.

Section 11

This section delegates the submittal of reports required by 50 USC 1641(c) and 50 USC 1703(c) to the Secretary of the Treasury.

Section 12

This section defines the date and time at which the Executive Order comes into force.

Section 13

This section includes the legal fine print necessary to ensure compliance with the constitutional limits on the executive branch.

Annex

In the Annex are listed 13 persons from all over the world.

My commentary

I honestly cannot remember what, if any, international events might have lead up to the issue of the particular Executive Order.  It is of the type wherein the forces of normalcy had snuck in and wrested a victory from the jaws of chaos that have normally consumed the administration.  However, I really have some angst with the fact that human rights abuses and corruption in general are being used as a justification to invoke a national emergency.  It would make more sense if there was a particular instance that needed to be made an example of.  The pre-amble is weak in the justifications provided.  That's not to say I disagree with taking action against the people listed in the Annex.  There was something political in framing it through a) scare tactics and b) through a Presidential Executive Order rather than simply pursuing justice through the Justice Department and Intelligence agency black ops.
The text itself should have been almost boilerplate, if you run a search on Proclamation 8693, you can see that this kind of thing has been issued on a regular, maybe infrequent, but certainly regular basis and yet Section 4 of the EO looks like it was jammed in there at the last minute before signing.