Executive Order on Taking Additional Steps with Respect to the Situation in the Western Balkans (EO 14140)

Date issued: Jan. 08 2025

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TURBOFAC Commentary (122 words)

Notes:

1) This EO amends Executive Order 14033 to made the changes to section 1 found in the redline of the PDF file. The EO expands the designation authorities by adding "attempts" to engage in activities described in section 1(a)(i)-(v), adding 1(a)(vi), and adding 1(a)(ix)-(x). The designation criterion for "own or control, directly or indirectly, any person whose property and interests in property are blocked pursuant to this order" is extremely rare (seemingly only in Executive Order 13886, apart from this EO). This means that OFAC can, for example, designate an ordinary company for providing material assistance to a given blocked person (e.g. through ordinary commercial transactions), and then designate any person that owns or controls the derivatively designated entity.