Re-Designation Stymies Potential Sanctions Revanchists

Posted 1/15/25

In a move some read as an effort to "Trump Proof" the Treasury's Russian sanctions regime, OFAC is re-designating pursuant to Executive Order (E.O.) 13662 almost 100 entities already designated pursuant to E.O. 14024. This codification provides legislative backing, making it more difficult for any administration to unilaterally lift these sanctions.

This move places the sanctions under rules governed by the Countering America’s Adversaries Through Sanctions Act (CAATSA). CAATSA, enacted in 2017, codified and expanded existing sanctions imposed by executive orders, including E.O. 13662.

As a result of these entities’ designation pursuant to E.O. 13662, foreign persons, including foreign financial institutions, that knowingly facilitate significant transactions for or on behalf of any of these entities could be subject to mandatory secondary sanctions under the Ukraine-/Russia-related sanctions program. 

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