Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.
Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).
Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category).
Please contact [email protected] or [email protected] with any questions on search results and efficiency.
Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.
[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...