887. Are persons identified pursuant to Executive Order (E.O.) 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy blocked pursuant to E.O. 14024?
Persons identified pursuant to E.O. 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy are not subject to prohibitions under E.O. 14024 unless those persons are also sanctioned pursuant to E.O. 14024. For more information regarding Directive 3, please review applicable OFAC public guidance, such as FAQ 411.
E.O. 14024 provides for blocking sanctions on persons operating in the technology sector or the defense and related materiel sector of the Russian Federation economy, or any other sectors determined by the Secretary of the Treasury, in consultation with the Secretary of State. The identification of a sector pursuant to E.O. 14024 provides notice that persons operating in the identified sector are exposed to sanctions risk; however, such identification does not automatically block all persons operating in the sector. Only persons designated pursuant to E.O. 14024 for operating in the defense and related materiel sector of the Russian economy (or any other sector identified under the E.O.) are subject to blocking sanctions and will appear on the SDN List.
E.O. 14024, as amended by E.O. 14114, also authorizes the imposition of sanctions on foreign financial institutions that have conducted or facilitated certain transactions involving Russia’s military-industrial base. See FAQs 1147, 1148, 1149, 1150 and 1151 for information.
Date Updated: February 23, 2024
Date Released
April 15, 2021
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887. Are persons identified pursuant to Executive order (E.O.) 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy blocked pursuant to the E.O. of April 15, 2021?
Persons identified pursuant to E.O. 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy are not subject to prohibitions under the E.O. of April 15, 2021 unless those persons are also sanctioned pursuant to the E.O. of April 15, 2021. For more information regarding Directive 3, please review applicable OFAC public guidance, such as FAQ 411.
The E.O. of April 15, 2021 provides for blocking sanctions on persons operating in the technology sector or the defense and related materiel sector of the Russian Federation economy, or any other sectors determined by the Secretary of the Treasury, in consultation with the Secretary of State. The identification of a sector pursuant to the E.O. of April 15, 2021 provides notice that persons operating in the identified sector are exposed to sanctions risk; however, such identification does not automatically block all persons operating in the sector. Only persons designated pursuant to the E.O. of April 15, 2021 for operating in the defense and related materiel sector of the Russian economy (or any other sector identified under the E.O.) are subject to blocking sanctions and will appear on the SDN List.
Date Released
April 15, 2021
1) This is another way of saying that even if a person is squarely within the scope of a designation criterion, such as designation criterion at Section 1(a)(i) of EO 14024 that pertains to “operating in” the defense sector of the Russian Economy, a person is not blocked pursuant to that authority absent an “affirmative determination” by the responsible component of the USG. See General Note on "Sectoral Sanctions" and Determinations Made Pursuant to EOs Providing for the Blocking of Persons Determined to "Operate In" a Certain Sector.
As of 4/15/2021, there are two separate criteria pursuant to which persons can be designated for operating in the defense sector of the Russian economy. One is EO 13662 and the other is EO 14024. EO 14024 will, presumably, be used to deal with defense sector-related persons deemed to merit harsher sanctions than the defense sector-related persons that are made subject to SSI Directive 3 under EO 13662.
2) FAQ amended on 2-23-24 to add the following:
E.O. 14024, as amended by E.O. 14114, also authorizes the imposition of sanctions on foreign financial institutions that have conducted or facilitated certain transactions involving Russia’s military-industrial base. See FAQs 1147, 1148, 1149, 1150 and 1151 for information.