Appendix A to Part 582—Executive Order 13851 of November 27, 2018 [Blocking Property of Certain Persons Contributing to the Situation in Nicaragua]

Date issued: Nov. 27 2018

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TURBOFAC Commentary (1335 words)

Note Common to EO 13851, as amended by EO 14088, the Nicaragua Human Rights and Anticorruption Act of 2018 and the Nicaragua Investment Conditionality Act of 2018

1) The prohibitions of EO 13851, as amended by EO 14088, are incorporated by reference in 582.201. See comments to 582.201 concerning the administration of the blocking prohibitions contained in this EO.

2) The designation criteria in the original version of EO were 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;...