FEND off Fentanyl Act (2024 "National Security Supplemental" - Public Law No: 118-50)

Date issued: Apr. 24 2024

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TURBOFAC Commentary (297 words)

Notes:

1) This is one of a dozen or so sanctions related provisions of the 2024 "National Security Supplemental". Compare Sec. 7201 et seq. of the FY 2020 NDAA (“Fentanyl Sanctions Act”) and Executive Order 14059 (2021). While section 7217 of the Supplemental (the “FEND off Fentanyl Act”) is a sanctions program apart from the broader “Illicit Drugs” EO (14059) and the Fentanyl Sanctions Act, there does not appear to be much if anything that is sanctionable under the FEND off Fentanyl Act that isn’t already sanctionable under one or both of the other two authorities.

2) As is the case with the Fentanyl Sanctions Act, one might expect OFAC to rarely, if ever, actually designate persons pursuant to this authority. Any person identified in the report required...