Sanctions-related Statute - Sec. 7201 et seq. of the FY 2020 NDAA (“Fentanyl Sanctions Act”)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (1304 words)

Notes:

1.0) IN GENERAL

The Fentanyl Sanctions Act ("FSA") is roughly modeled on the Foreign Narcotics Kingpin Designation Act ("FNKDA") which serves as the basis for the Foreign Narcotics Kingpin Sanctions Regulations ("FNKSR").

On Dec. 15, 2021, Executive Order 14059 "implemented" the FSA with an -based sanctions authority. See comments to Executive Order 14059 for the relationship between that and the FSA. In all likelihood, no persons will actually be designated "pursuant to" the FSA, with EO 14059 serving to satisfy the congressional mandates contained in the FSA with an IEEPA-based authority. This does not change the analysis below, but note that it was drafted prior to the issuance of EO 14059, when it still seemed possible that designations would be made pursuant...

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Sec. 7201 et seq. of the FY 2020 NDAA (“Fentanyl Sanctions Act”)

TURBOFAC Commentary (1304 words)