Blocking Property of Additional Persons Contributing to the Situation in Ukraine

This executive order expands U.S. sanctions against Russia by authorizing the Treasury Secretary, in consultation with the Secretary of State, to block property and interests of persons operating in key Russian economic sectors including financial services, energy, metals and mining, engineering, and defense. It also suspends entry into the United States of aliens meeting the designated criteria.

Federal Register Open PDF 79 FR 16169

Impact dates

Mar 20, 2014
Effective date of property blocking and entry suspension

Key directives

Block all property and interests in property of persons determined to operate in designated Russian economic sectors
Secretary of Treasury, in consultation with Secretary of State, to determine applicable sectors including financial services, energy, metals and mining, engineering, and defense
Suspend immigrant and nonimmigrant entry of aliens meeting section 1(a) criteria
Prohibit donations of articles specified in IEEPA section 203(b)(2) to blocked persons
Prohibit evasion, avoidance, and conspiracy to violate order prohibitions
No prior notice required for listing or determination under section 1
Secretary of Treasury authorized to promulgate rules and regulations to carry out order

Who is ordered

Timeline

Immediate

Property blocking authority takes effect upon signing
Entry suspension effective immediately for designated persons

Near term (90d)

Treasury Secretary sectoral determinations expected
Implementing regulations and guidance anticipated
OFAC list updates and designations

Long term

Ongoing sanctions enforcement and compliance monitoring
Potential expansion to additional sectors
Diplomatic leverage in Ukraine crisis

Risks & tensions

Sectoral sanctions framework creates uncertainty: 'such as' language lists examples but does not limit Treasury's authority to additional sectors
No prior notice requirement (Sec. 7) raises due process concerns for U.S.-connected persons
Broad 'materially assisted' standard in 1(a)(ii) creates compliance risk for international businesses
Reliance on Treasury-State consultation without explicit congressional oversight mechanism
Vague 'operate in' standard for sectoral determination leaves significant discretion