E.O. 14071 - Efforts To Prohibit New Investment in and Certain Services in Response to Continued Aggression

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 (1464 words)

Notes:

1) BACKGROUND:

This is highly irregular, containing (i) "new investment" prohibitions applying to the entirety of an otherwise non-embargoed country, and (ii) authorization for future prohibitions related to "categor[ies] of services". The EO also contains an explicit facilitation prohibition (which would otherwise imply on an implicit basis. See General Note on Explicit and Implicit "Facilitation" Prohibitions in -based Embargoes).

Note that these prohibitions operate independent of prohibitions imposed pursuant to EO 14024, even though the activities prohibited by this EO are prohibited by 587.201(b) of the Russian Harmful Foreign Activities Sanctions Regulations (“All transactions prohibited pursuant to any further Executive orders issued pursuant to the national emergency declared in E.O. 14024 are prohibited pursuant to this part.”) Refer to General Note on the Relationship...

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E.O. 14071 - Efforts To Prohibit New Investment in and Certain Services in Response to Continued Aggression

TURBOFAC Commentary (1464 words)