On July 17, 2007, President Bush issued Executive Order 13438, Blocking Property of Certain Persons Who Threaten Stabilization Efforts in Iraq. It is the latest in a series of executive orders based on the national emergency declared by President Bush with respect to "the unusual and extraordinary threat to the national security and foreign policy of the United States posed by obstacles to the orderly reconstruction of Iraq, the restoration and maintenance of peace and security in that country, and the development of political, administrative and economic institutions in Iraq." The broad language of this executive order has been the subject of a degree of criticism as potentially reaching beyond insurgents in Iraq to third parties, such as U.S. citizens, who may unknowingly be providing support for the insurgency. Having declared a national emergency, the President invoked authority available under the International Emergency Economic Powers Act of 1977 (IEEPA) and ordered the blocking of financial transactions and the institution of property controls with respect to any property or interests in property of persons determined to fall within three categories of individuals or entities threatening the stabilization efforts in Iraq. Implementation of this executive order is the responsibility of the Department of the Treasury's Office of Foreign Assets Control (OFAC), which currently "administers economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries, terrorists, international narcotics traffickers, and those engaged in activities related to the proliferation of weapons of mass destruction." OFAC has promulgated regulations implementing sanctions involving the Balkans, Belarus, Burma, Cote d'Ivoire (Ivory Coast), Cuba, diamond trading, Iran, Iraq, Liberia, Libya, narcotics trafficking, weapons of mass destruction proliferation, North Korea, Sudan, Syria, terrorists, and Zimbabwe. On September 13, 2010, OFAC issued regulations implementing Executive Order 13438 as well as various other Executive Orders issued since 2003 to deal with the situation in Iraq. These regulations, the Iraq Stabilization and Insurgency Sanctions Regulations, 31 C.F.R., Part 576, elaborate to some extent on the Executive Order. For instance, they specify that the blocking orders for persons sanctioned under Executive Order 13438 are effective on "the earlier of the date of actual or constructive notice that such person's property and interests in property are blocked," rather than, for example, on the date of publication in the Federal Register of the person's designation as a Specially Designated Terrorist. The regulations also declare to be blocked any property or interests in property of any entity in which the blocked person has, directly or indirectly, a 50% interest, whether or not that entity has been designated under the Executive Order. Persons whose interests have been blocked may challenge the blocking orders in two ways. If they can claim "mistaken identity," they may seek to have the funds or property released by observing the procedures specified in 31 C.F.R. § 501.806. They also have the possibility of seeking administrative review of their designation as a Specially Designated Terrorist by showing that the basis on which they have been designated is "insufficient" or by proposing "remedial steps" that they could take to "negate the basis for designation." A list of designees added to OFAC's Special Designated Nationals and Blocked Persons List under Executive Order 13438 was issued by Treasury on January 9, 2008. It included Ahmed Fruzandeh, Brigadier General, Commanding Officer of the Iranian Islamic Revolutionary Guard Corps-Qods Force, Ramazan Corps, who "leads terrorist operations against Coalition Forces and Iraq Security Forces, and directs assassinations of Iraqi figures." Also included were two Iran-based Iraqi nationals, and one Syria-based Iraqi national as well as Al-Zawra Television Station, based in Syria. The Treasury announcement includes a description of the activities of the designees that have led to the prohibition of transactions between them and any U.S. person and the freezing of any of their assets that are under the jurisdiction of the United States. On September 23, 2008, the names of five newly designated individuals and two newly designated entities were added to the list of blocked persons and entities under the authority of Executive Order 13438. One Iranian national was included, as were three Iraqi nationals, and one Syrian national. The newly designated entities were both broadcasters operating in Syria: Al-Ra'y Satellite Television Channel, Near Damascus in the Yaafur area, and Suraqiya for Media and Broadcasting, Damascus. On July 16, 2009, OFAC announced the names of one newly designated entity and one newly designated individual whose property and interests in property are blocked pursuant to Executive Order 13438. On January 5, 2010, OFAC added the following designee to the list of entities and individuals whose property is blocked pursuant to Executive Order 13438: Jaysh Rijal Al-Tariq Al-Naqshabandi (a.k.a. Armed Men of the Naqshabandi Order; a.k.a. Naqshabandi Army; a.k.a. "AMNO"; a.k.a. "JRN"; a.k.a. "JRTN"), Iraq; website: http://www.alnakshabandia-army.org ; http://www.alnakshabandia-army.com [IRAQ3]. On January 10, 2012, OFAC removed the following individual from the list of blocked persons: Dr. Safa Al Habobi, Flat 4D Thorney Court, Palace Gate, Kensington, United Kingdom (former Minister of Oil). On July 7, 2012, OFAC removed the following entities from the list of blocked persons: Alfa Company Limited for International Trading and Marketing, P.O. Box 910606, Amman 11191, Jordan; Nabil Victor Karman, c/o Alfa Company Limited for International Trading and Marketing, P.O. Box 212953, Amman 11121, Jordan; Trading and Transport Services Company, Ltd., Al-Razi Medical Complex, Jabal Al-Hussein, Amman, Jordan; P.O. Box 212953, Amman 11121, Jordan; P.O. Box 910606, Amman 11191, Jordan [IRAQ2]. On January 3, 2013, OFAC removed one entity and one individual from the list of Designated Nationals and Blocked Persons: Euromac European Manufacturer Center SRL, Via Amerer 5, Monza Italy; and Jeanne Speckman of the United Kingdom. The July 17, 2007, executive order cites as its authority IEEPA. Under IEEPA, once the President has declared a national emergency with respect to a threat "to the national security, foreign policy, or economy of the United States" from a source "in whole or in substantial part outside the United States," broad authority is available to the President to impose an economic embargo over transactions and property in which a foreign nation or foreign person has an interest. Specifically, the statute authorizes the President to (A) investigate, regulate, or prohibit— (i) any transactions in foreign exchange, (ii) transfers of credit or payments between, by, or through, or to any banking institution, to the extent that such transfers or payments involve any interest of any foreign country or national thereof; and (iii) the importing or exporting of currency or securities ... and (B) investigate, regulate, direct and compel, nullify, void, prevent or prohibit, any acquisition, holding, withholding, use, transfer, withdrawal, transportation, importation or exportation of, or dealing in, or exercising any right, power, or privilege with respect to, or transactions involving, any property in which any foreign country or a national thereof has any interest; by any person, or with respect to any property, subject to the jurisdiction of the United States. This language is derived from section 5(b) of the Trading with the Enemy Act of 1917 (TWEA), which grants authority to the President to block and freeze enemy property and interests in property and to regulate financial transactions involving enemy countries, their nationals and their allies during a declared war. It was first used in peacetime in 1933, in the midst of the Great Depression, when President Franklin D. Roosevelt proclaimed a bank holiday and closed banks in the United States, thereby interfering with both foreign and domestic financial transactions, in response to what he deemed to be a national banking emergency related to "extensive speculative activity abroad in foreign exchange ... [resulting] in severe drains on the Nation's stocks of gold." Congress immediately ratified this action and amended TWEA, extending the emergency powers granted under the original legislation to cover both wartime and "any other period of national emergency declared by the President" and provided the President with authority to regulate purely domestic transactions. President Roosevelt invoked TWEA again in peacetime in 1939, as Hitler was advancing in Europe, to block assets of Norway and Denmark and their nationals. Eventually TWEA was used to block assets of the Axis enemies of the United States. A 1940 amendment expanded presidential power under TWEA by specifically authorizing asset freezes and expanding authority beyond transactions with enemies or allies of enemies to cover financial transactions in which any foreign state or foreign national had an interest. TWEA, thus, was used to block assets of friendly nations threatened by Axis occupation. A 1941 amendment to TWEA added the power to seize and vest title to any property of a foreign person or nation. This amendment extended the "power of seizure ... to all property of any foreign country or national so that no innocent appearing device could become a Trojan horse," i.e., it was designed "to reach enemy interests which masqueraded under ... innocent fronts."