The Zimbabwe sanctions program implemented by the Office of Foreign Assets Control (“OFAC”) began on March 7, 2003, when the President issued Executive Order (“E.O.”) 13288. E.O. 13288 imposed sanctions against specifically identified individuals and entities in Zimbabwe, as a result of the actions and policies of certain members of the Government of Zimbabwe and other persons undermining democratic institutions or processes in Zimbabwe. Following E.O. 13288, in response to the continued undermining of democratic institutions, the President issued two subsequent Executive orders that expanded the list of sanctions targets to include immediate family members of any person whose property and interests in property are blocked as well as those persons providing assistance to any such individual.
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