Executive Order 14059 - Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade

Date issued: Dec. 15 2021

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TURBOFAC Commentary (1672 words)

Notes:

[Update - on 12-20-22, this EO was implemented into the CFR in abbreviated format at part 599 (see 599.101 et seq., the "Illicit Drug Trade Sanctions Regulations"). The IDTSR contain a few definitional provisions that relate to the designation criteria discussed below. Otherwise, the regulations are standard abbreviated blocking regulations]

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1) BACKGROUND

EO 14059 implements, and expands on pursuant to the President’s IEEPA powers, the Fentanyl Sanctions Act (Sec. 7201 et seq. of the FY 2020 NDAA) (“FSA”)

The EO is highly irregular in a number of significant ways, especially as it relates to designation criteria. In general, it appears to continue with the trend, recent as of the date of the issuance...