Executive Order on Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation (EO 14024)

Date issued: Apr. 15 2021

Last substantive commentary amendment:
Dec. 22 2023

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TURBOFAC Commentary (2088 words)

Notes:

[12-23-23 Update - on 12-22-23, The President issued EO 14114, which amended EO 14024 to add a section 11 authorizing the imposition of CAPTA and blocking sanctions on FFIs that have engaged in certain types of sanctionable activity. See comments to EO 14114 for further commentary, and note that the below has not been amended to account for new section 11.]

1) BACKGROUND; RELATION TO PRE-EXISTING RUSSIA-RELATED SANCTIONS AUTHORITIES

EO 14024, which was issued on April 17, 2021, establishes a new Russia-related “national emergency.” From a substantive perspective, the new “national emergency” overlaps significantly with national emergencies declared under other executive orders. The designation criteria set out in the EO include authorities to designate persons involved in (i) “malicious cyber-enabled activities” (compare EO 13694), (ii) “interference...