Imposing Certain Sanctions on Persons Undermining Peace, Security, and Stability in the West Bank
Executive Order 14115, signed by President Biden (effective February 1, 2024), uses the President’s emergency powers to impose targeted sanctions on persons deemed to undermine peace, security, and stability in the West Bank. The order designates individuals or foreign entities (and their property) who are responsible for, or complicit in, violence, displacement, or property destruction in the West Bank, including leaders of blocked entities or those who materially support them. It blocks their property and interests in U.S. jurisdiction, restricts their ability to transfer funds or receive support, and imposes visa/entry restrictions on non-U.S. persons connected to these designations. The order also provides for regulations and reporting, and it explicitly states that the measures may be implemented without prior notice to those listed. In short, the order expands U.S. sanctions tools to target specific actors connected to harmful actions in the West Bank, aiming to deter violence, displacement, and property crimes while seeking to protect broader U.S. interests and regional stability.
Key Points
- 1Grounds for designation and scope of sanctions
- 2- Section 1 authorizes the Secretary of State (in consultation with the Secretary of the Treasury) or the Secretary of the Treasury (in consultation with the Secretary of State) to block the property and interests in property of foreign persons who are responsible for or complicit in, or who have engaged in, actions that threaten peace, security, or stability in the West Bank. This includes planning or participating in violence against civilians, forced displacement, property destruction, or private seizure of property; and leaders or officials of entities involved in these activities; or those who materially assist or are owned/controlled by such persons.
- 3Who can be designated and what “blocked” means
- 4- Designations can target individuals or entities (including government entities) tied to the described activities. “Blocked” means their property and interests in property in the United States or under U.S. control are frozen and may not be transferred, paid, exported, withdrawn, or dealt in.
- 5Immigration and entry restrictions
- 6- Section 4 imposes suspension of entry into the United States (as immigrants or nonimmigrants) for noncitizens who meet the criteria, with possible exceptions if entry would not serve U.S. interests or would support law enforcement objectives. Visa and entry procedures are to be established and administered by the State Department and Homeland Security.
- 7Prohibitions beyond asset blocking
- 8- Section 3 makes clear prohibitions on providing or receiving funds, goods, or services to or from blocked persons. Section 5 prohibits evading these prohibitions and any conspiracies to violate them.
- 9No prior notice for designation
- 10- Section 8 allows for listing/acting against individuals without prior notice if notification would undermine the effectiveness of measures.
- 11Implementation, oversight, and reporting
- 12- Section 9 authorizes the Treasury (in concert with the State Department) to issue rules/regulations and to exercise all IEEPA powers as needed. Agencies must implement the order; Section 11 requires ongoing reports to Congress about the national emergency and its administration.
- 13Legal scope and limitations
- 14- Section 2 clarifies that prohibitions apply unless otherwise provided by law or future regulations, and do not affect preexisting contracts or licenses except as regulated. Section 12 confirms the order does not grant rights or remedies and that its implementation must comply with applicable law and appropriations.