Executive Order on Blocking Property of Additional Persons Contributing to the Situation in Belarus (EO 14038)

Date issued: Aug. 09 2021

Last substantive commentary amendment:
Mar. 27 2023

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TURBOFAC Commentary (742 words)

Notes:

1) Executive Order 14038 is, except as discussed below, a fully regular, IEEPA-based blocking executive order that is not yet associated with implementing regulations. On 3-27-23, the EO was implemented in the BeSR. See 548.201.

2) One irregular aspect of the EO vis-a-vis the typical sanctions related EO is that the EO expands the scope of a pre-existing national emergency. The significance of this is discussed in detail in General Note on the Relationship Between Executive Orders, General Licenses and Sanctions Regulations Issued Pursuant to a Common National Emergency.

3) The designation criteria in this EO are regular, with certain “primary” designation criteria not of interest to the typical legitimate commercial actor, along with the standard “derivative designation”...