Obama Issues Information Technology Sanctions on Iran and Syria

April 24, 2012

On April 22, 2012, President Obama signed an Executive Order, establishing sanctions against those complicit in using information technology to carry out grave human rights abuses in Syria and Iran. In the Executive Order, the President notes that computer and network disruption, monitoring, and tracking by the Syrian and Iranian governments and by complicit entities in Iran and Syria, have facilitated the commission of human rights abuses against the people of Iran and Syria which threaten the national security and foreign policy of the United States. The sanctions established in the Executive Order are primarily designed to prevent entities located in whole or in part in Iran and Syria from facilitating or committing serious human rights abuses. According to the White House, the financial and travel sanctions established against those who perpetrate or facilitate “Grave Human Rights Abuses Via Information Technology” in Syria and Iran, are expected to (1) reduce the Syrian and Iranian governments’ ability to acquire and utilize technology such as satellite communications, mobile phones, and internet technology, (2) send a message that the United States is committed to combatting this new human rights threat, (3) further isolate the Syrian and Iranian regimes, and (4) strengthen international norms against using information and communications technology to commit human rights abuses. The Executive Order takes effect April 23, 2012.  

The Executive Order blocks the property and interests in property, and suspends entry into the United States, of persons determined by the Secretary of the Treasury, in consultation with the Secretary of State:

• To have operated, or to have directed the operation of, information and communications technology that facilitates computer or network disruption, monitoring or tracking that could assist in or enable serious human rights abuses by or on behalf of the Government of Iran or the Government of Syria;
  
• To have sold, leased, or otherwise provided, directly or indirectly, goods, services, or technology to Iran or Syria likely to be used to facilitate computer or network disruption, monitoring or tracking that could assist in or enable serious human rights abuses by or on behalf of the Government of Iran or the Government of Syria;
  
• To have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, those activities; or
  
• To be owned or controlled by, or have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to the order.

 

The Executive Order additionally blocks all property and interests in property of the following individual and six entities:

• Ali MAMLUK – director of the Syrian General Intelligence Directorate
  
• Syrian General Intelligence Directorate
  
• Syriatel
  
• Islamic Revolutionary Guard Corps
  
• Iranian Ministry of Intelligence and Security
  
• Law Enforcement Forces of the Islamic Republic of Iran
  
• Datak Telecom

All property and interests in property that are in the United States, that come within the United States, or that come within the possession or control of any United States person, including any foreign branch, of the listed persons may not be transferred, paid, exported, withdrawn, or otherwise dealt in.

For further information, please contact a Barnes/Richardson attorney.