Executive Order on Blocking Property with Respect to Certain Russian Energy Export Pipelines (EO 14039)

Date issued: Aug. 20 2021

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TURBOFAC Commentary (679 words)

Notes:

1) As explained in FAQ # 921, this EO was issued “blocking of PEESA-designated persons without the exception relating to the importation of goods in Section 7503(e) of PEESA”. When a person is blocked pursuant to a statute that contains an “import exception” the “import exception” does not apply when that person is blocked pursuant to multiple authorities at least one of which does not contain the import exception. See generally General Note on "Import Exceptions" in Certain Program-Specific Sanctions Statutes.

2) This EO was “in order to take additional steps with respect to the national emergency declared in Executive Order 14024 of April 15, 2021”. This does not, however, mean that there is any legal relationship between the EO 14024 prohibitions and the prohibitions contained in...