IEEPA - 50 USC Sec. 1702 - IEEPA Presidential Authorities, 50 USC Sec. 1705 - IEEPA Penalties, as amended

Date issued: Apr. 24 2024

Last substantive commentary amendment:
May. 04 2024

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TURBOFAC Commentary (1895 words)



In conjunction with the National Emergencies Act, IEEPA, and especially Sec. 1702, provides the primary statutory authority for the vast majority of all OFAC-administered sanctions programs. Other sanctions statutes, such as the Global Magnitsky Human Rights Accountability Act, call for asset blocking in a way that cross-references the powers granted to the President pursuant to IEEPA, such that the interpretation of this statute effectively controls the scope and operation of sanctions imposed pursuant to other programs as well.

In at least an indirect sense, virtually every sanctions related judicial opinion, regulation, enforcement action and interpretive guidance letter is an interpretation of IEEPA, insofar as this statute sets the boundaries of what OFAC may and may not do, and all of OFAC's decisions are implied statements that such actions are within the...