Executive Order 13849 - Authorizing the Implementation of Certain Sanctions Set Forth in the Countering America's Adversaries Through Sanctions Act (September 20, 2018)

Date issued: Sep. 20 2018

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TURBOFAC Commentary (3321 words)

Notes:

1) Read in conjunction with "Presidential Memorandum for the Secretary of State, the Secretary of the Treasury, and the Director of National Intelligence" (September 29, 2017), [1] which apportions the implementation of parts of CAATSA between State and Treasury (OFAC). This EO pertains only to the Russia-related portion of CAATSA (Title II).

In its "Notice of OFAC Implementation of Certain Sanctions Imposed on Two Persons by the Secretary of State Pursuant to the Countering America's Adversaries Through Sanctions Act" (83 FR 52051), OFAC confirmed the following:

"The Secretary of the Treasury is responsible for implementing the following sanctions under CAATSA: (i) Prohibiting any United States financial institution from making loans or providing credits to the sanctioned person totaling more than $10,000,000 in any 12-month period, unless the person is engaged...