On April 24, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 271 employees of Syria’s Scientific Studies and Research Center (“SSRC”) pursuant to Executive Order 13582 (targeting the Syrian government and its supporters).  The designations are part of the Trump Administration’s response to the April 4, 2017 chemical weapons attack in Khan Sheikhoun, Syria, carried out by the Syrian government.  According to the OFAC press release, the targeted individuals “have expertise in chemistry and related disciplines and/or have worked in support of SSRC’s chemical weapons program since at least 2012.” The new designations come on the heels of a U.S. missile strike against the Syrian airbase from which the chemical attack was launched.

Pursuant to the designations, the property and interests in property of the sanctioned individuals, to the extent located in the United States or in the possession or control of a U.S. person, are blocked. Essentially, this means that all U.S. persons worldwide are required to freeze the sanctioned persons’ assets and are cut off from all transactions and dealings with them.

This marks the second time this year the U.S. has imposed sanctions on Syrian persons involved with the government’s chemical weapons program.  On January 12, 2017, the Obama Administration imposed sanctions against Syrian government officials and entities connected to the Syrian chemical weapons program after an investigation by the Organization for the Prohibition of Chemical Weapons and the United Nations found that the Syrian government was behind three chlorine gas attacks.

The OFAC press release describes the April 24 designations as “one of the largest sanctions actions in its history” and notes that it “more than doubles in a single action the number of individuals and entities sanctioned by the United States pursuant to Syria-related Executive Orders.”

The action is notable not only for the number of individuals designated, but also for its approach of designating individual employees rather than just the SSRC itself. This differs somewhat from previous the approach of previous administrations, which typically have designated entities or senior officials, but not a large group of individual employees associated with one specific entity.  It is unclear whether the Trump Administration’s decision to designate individual employees represents a shift in sanctions strategy or whether it will revert to the more traditional approach of sanctioning entities and senior officials.  Perhaps providing a window into its thinking, the Administration noted that the designated individuals were “highly educated” and likely to be able to engage in international travel and use of the international financial system.