Executive Order on Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia (EO 14046)

Date issued: Sep. 17 2021

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TURBOFAC Commentary (736 words)

Notes:

[2-09-2022 Update - the prohibitions of this EO has been implemented into the Ethiopia Sanctions Regulations (Part 500), and the EO is reproduced as Appendix A to Part 550].

1) BACKGROUND

From a policy and technical standpoint, EO 14046 is irregular in a number of ways vis-à-vis the typical country or region-specific sanctions EO. From a policy standpoint, the EO is irregular in that (i) no persons were actually sanctioned pursuant to the EO on the date it was issued, and (ii) the “targets” of the EO could be any one of a number of warring factions that fail to negotiate peace on the terms desired by the USG. (See the State Department’s statement, issued on the day of the issuance of the EO [1]. On Sep. 20, 2021, the State Department...