Executive Order 13818 [Blocking the Property of Persons Involved in Serious Human Rights Abuse or Corruption]

Date issued: Dec. 20 2017

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TURBOFAC Commentary (860 words)

Note Common to EO 13818 and the Global Magnitsky Human Rights Accountability Act of 2016

1) The prohibitions of EO 13818 are incorporated by reference in 583.201. See comments to 583.201 concerning the administration of the blocking prohibitions contained in the EO.

2) The designation criteria in EO 13818 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 for or on or 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).