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MemoMemorandumObama · D Quiet signal

Presidential Memorandum

Delegation of Certain Functions Under Section 6 of Public Law 112-150

This memorandum delegates presidential functions under Section 6 of the Sergei Magnitsky Rule of Law Accountability Act of 2012 (Public Law 112-150) to the Secretary of State, to be exercised in coordination with the Secretary of Defense. The delegated functions involve identifying and imposing sanctions on individuals responsible for gross violations of human rights in Russia.

Federal Register Open PDF 78 FR 5705

Impact dates

  1. Federal Register publication

Key directives

  • Delegate all functions under subsections (a) and (b) of section 6 of Public Law 112-150 to Secretary of State
  • Exercise functions in coordination with Secretary of Defense
  • Publish memorandum in Federal Register

Who is ordered

Timeline

Immediate

  • Delegation of presidential functions to Secretary of State takes effect
  • Secretary of State authorized to impose sanctions under Magnitsky Act provisions

Near term (90d)

  • Secretary of State to develop lists of sanctioned individuals in coordination with Secretary of Defense
  • Federal Register publication of memorandum

Long term

  • Ongoing implementation of Magnitsky Act sanctions regime
  • Potential expansion of sanctions based on human rights violations

Risks & tensions

  • Interagency coordination requirement between State and Defense may create friction
  • Low public visibility belies significant foreign policy tool for human rights pressure
Presidential Memorandum: Delegation of Certain Functions Under Section 6 of Public Law 112-150 · Executive Orders