Appendix A to Part 569 — Executive Order 13894, As Further Amended Executive Order 13894 of October 14, 2019, As Further Amended by Executive Order 14142 of January 15, 2025 and Executive Order 14312 of June 30, 2025 Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria

Date issued: Sep. 24 2025

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TURBOFAC Commentary (1619 words)

Notes:

*Update. On Oct. 23, 2019, OFAC de-listed all five entities and individuals blocked pursuant to the EO. The below was drafted prior to the delisting.

*On Jun. 5, 2020, OFAC issued abbreviated regulations implementing the EO, which is now Appendix A to Part 569—Executive Order 13894.

* On Jan. 16, 2025, this EO was amended by Executive Order on Taking Additional Steps with Respect to the Situation in Syria.

* On Sep. 24, 2025, this EO was republished in the CFR to incorporate the amendments thereto.

1) INTRODUCTION; RELATIONSHIP TO PRE-EXISTING SYRIA-RELATED SANCTIONS

This EO, issued in response to actions by the Turkish military in Northeastern Syria, is highly irregular for a number of reasons discussed below, but in general does not present any novel legal...