General Note on "Abbreviated Regulations" and Executive Orders with Standard Blocking Prohibitions not yet Implemented in the CFR (System Ed. Note)

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TURBOFAC Commentary (4869 words)

General Note on "Abbreviated Regulations" and Executive Orders with Standard Blocking Prohibitions not yet Implemented in the CFR (System Ed. Note)

There are several executive orders that impose blocking sanctions in a "list-based" fashion that have not yet been the subject of regulatory implementation. By "list based," we refer to prohibitions that operate solely with reference to persons that have been affirmatively determined to meet one or more designation criteria, with the 50% rule blocking all persons owned 50% or more by any combination of blocked persons. Similarly, there are around 14 sets of sanctions regulations that implement list-based EOs into regulations, but with the provision that they are published in abbreviated form for the purpose of providing immediate guidance to the public..." Note that all of the "abbreviated" regulations are standard, list-based blocking programs. A characteristic of virtually all of...