Executive Order Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security And Foreign Policy

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.

TURBOFAC Commentary (406 words)

Notes:

1) This , for the first time ever, authorizes the imposition of “secondary sanctions” on non-U.S. persons for dealings involving Cuba.

2) Notable aspects of the EO include:

(a) A broad range of Cuba-specific targeting authorities, including operating in “in the energy, defense and related materiel, metals and mining, financial services, or security sector of the Cuban economy,” and having “materially assisted…or provided financial, material, or technological support for, or goods or services to or in support of, the Government of Cuba.” (North Korea is currently only other government in the world of which the entirety is subject to such “material support” sanctions authority). Given the extent of “Government of Cuba” involvement in the Cuban economy, this designation authorization has the potential to cover substantially all trade involving Cuba except where authorized by

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Executive Order Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security And Foreign Policy

TURBOFAC Commentary (406 words)