Executive Order 13883 - on the Administration of Proliferation Sanctions and Amendment of Executive Order 12851

Date issued: Aug. 01 2019

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TURBOFAC Commentary (724 words)

Notes:

1) This EO implements a portion of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the CBW Act), and is the basis for the promulgation of the Russia-related Directive (the "CBW Act Directive") Issued Under E.O. 13883 of August 1, 2019. Of particular note for OFAC-administered sanctions purposes, the CBW Act authorizes the imposition of the following sanction, which was imposed on Russia.

"The United States Government shall prohibit any United States bank from making any loan or providing any credit to the government of that country, except for loans or credits for the purpose of purchasing food or other agricultural commodities or products."

As is evident, this EO imposes the sanction in language virtually identical to that used in the CBW Act, while defining the terms "U.S. Bank", "entity" and "government" in...