Executive Order on Bolstering Efforts to Bring Hostages and Wrongfully Detained United States Nationals Home

Date issued: Jul. 19 2022

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TURBOFAC Commentary (325 words)

Notes:

1) This EO, along with IEEPA, forms the basis for the Hostages and Wrongful Detention Sanctions Regulations (see 526.201).

1) Executive Order 14078 is, at least as it relates to the sanctions related portion in section 6, a fully regular, IEEPA-based blocking executive order that is associated with implementing regulations.

2) The designation criteria in this EO are 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; Identification of the Gap Between the...