On February 1, 2024, the United States introduced new sanctions to promote peace in the West Bank, targeting recent actions that jeopardize the region’s stability, including attacks by Israeli settlers against Palestinians and Palestinian attacks against Israelis. This follows the related visa restriction policy announced by the State Department on December 5, 2023. 

The sanctions have been introduced under a new Executive Order (E.O.) “Imposing Certain Sanctions on Persons Undermining Peace, Security, and Stability in the West Bank,” giving the authority to the U.S. Department of State and the U.S. Department of the Treasury to apply financial sanctions against persons who are contributing to the conflict and instability in the West Bank. The order aims to address the recent increase in violence, including attacks on civilians, and to hold those responsible accountable. It targets persons involved in activities that threaten peace, security, and stability in the region.

Following this E.O., the Department of the Treasury’s Office of Foreign Assets Control (OFAC) added four individuals to the Specially Designated Nationals (SDNs) and Blocked Persons List due to their roles in promoting conflict and instability in the West Bank. Additional persons may be designated pursuant to this E.O. by the Department of State or Department of the Treasury in the future.

In accordance with the new E.O., all property and interests in property of the designated persons that are in the United States or in possession or control of U.S. persons are blocked and must be reported to OFAC. Additionally, all entities that are owned, either directly or indirectly, 50% or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons are prohibited unless authorized by a general or specific license issued by OFAC or exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person. Additionally, the entry of designated individuals into the United States is suspended pursuant to Presidential Proclamation 8693.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.

Photo of Kristina Shcheglazova* Kristina Shcheglazova*

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control…

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control matters, including compliance with various sanctions and export control requirements, due diligence and sanctions screenings, and advises clients on the application of U.S. sanctions and export control licensing requirements. Her experience extends to addressing issues of forced labor in supply chains, assisting clients with government contracting matters and advising on anti-corruption policies.