It is an asset freeze (not just bank accounts) without due process.
I also find this part interesting:
"The prohibitions in subsection (a) of this section include, but are not limited to, (i) the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any person whose property and interests in property are blocked pursuant to this order, and (ii) the receipt of any contribution or provision of funds, goods, or services from any such person."
There are no words about scienter anywhere in that entire section. It therefore appears that you can be one of these "Certain Persons Who Threaten Stabilization in Iraq" just for having received a contribution of funds, even if you accept funds without knowing their source is one of these persons in section (a)(i).
It may be poor drafting, but I doubt it was accidental. By wording it without "knowingly" or "intentionally", or even "should have known", it gives "the Secretary of the Treasury, in consultation with the Secretary of State and the Secretary of Defense" complete discretion in determining who to go after.
Well, then...I guess certain "persons" will be more careful about the donations they receive. Claiming, "gosh, I didn't know that 700K in my bank account came from Hamas supporters just isn't going to cut it anymore.
see previous post.
Courts in Equity have long had the power to impress an equitable trust upon a res where the holder has no knowledge of wrongdoing.