EO 14098 - Executive Order on Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition

Date issued: May. 04 2023

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TURBOFAC Commentary (951 words)

Notes:

[UPDATE - On 3-5-24, OFAC implemented this EO into 31 CFR Part 546 and renamed the "Darfur Sanctions Regulations" the "Sudan Stabilization Sanctions Regulations". The below as not yet been amended to reflect this fact, but see generally General Note on the Darfur Sanctions Regulations and Underlying Authorities, EO 14098 and Relationship with the Sudanese Sanctions Regulations for more on the relationships between the various Sudan-related authorities.]

1) BACKGROUND; “COMMON NATIONAL EMERGENCY”

This EO “expand[s] the scope of the national emergency declared in Executive Order 13067 of November 3, 1997”—which is the national emergency that served as the basis for the now-repealed Sudanese Sanctions Regulations and the basis for the Darfur Sanctions Regulations—this EO is a sanctions program legally distinct from both of those. OFAC will, at some point in the...