Executive Order 13566 [Blocking Property and Prohibiting Certain Transactions Related to Libya]

Date issued: Feb. 25 2011

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TURBOFAC Commentary (401 words)

Notes:

1) The prohibitions of EO 13566 are incorporated by reference in 570.201. See comments to 570.201 concerning the administration of the blocking prohibitions contained in this EO.

2) Except as discussed below, 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” criteria, i.e. “materially assisting” blocked persons, acting on behalf of blocked persons and being owned or controlled by blocked persons. For comments on the administration of those standard designation criteria, refer to General Note on Secondary Sanctions and “Derivative Designation” Criteria; Identification of the Gap Between the Theoretical and Practical Scopes of Authorities Targeting Transactions with no U.S. Nexus; Enforcement Risk Management (System Ed. Note).

3) Sec. 2 of the EO blocks the entirety...