Authorizing the Implementation of Certain Sanctions Set Forth in the Countering America's Adversaries Through Sanctions Act

This executive order delegates presidential authority to impose specific sanctions under the Countering America's Adversaries Through Sanctions Act (CAATSA) and the Ukraine Freedom Support Act to the Secretaries of Treasury and State. It authorizes blocking property, restricting financial transactions, denying export licenses, excluding sanctioned individuals from the U.S., and other measures against persons determined to be subject to sanctions under those statutes.

Federal Register Open PDF 83 FR 48195

Key directives

Secretary of Treasury, in consultation with Secretary of State, shall implement financial sanctions (Sections 1, 3)
Heads of relevant departments and agencies shall implement trade, procurement, and visa sanctions (Sections 2, 4)
Export-Import Bank shall deny guarantees/credit for exports to sanctioned persons (Sections 2(a)(i), 4(a)(i))
U.S. executive directors at international financial institutions shall oppose loans benefiting sanctioned persons (Section 2(a)(iii))
Federal Reserve and Federal Reserve Bank of New York shall not designate sanctioned financial institutions as primary dealers (Section 2(a)(iv))
Secretary of State and Secretary of Homeland Security shall deny visas and exclude covered aliens (Sections 2(a)(vi), 4(a)(v))
Secretary of Treasury authorized to promulgate rules and regulations to carry out the order (Section 10)

Who is ordered

Timeline

Immediate

EO effective upon signing; sanctions mechanisms activated for persons already or subsequently designated

Near term (90d)

Potential designations and implementation of sanctions by Treasury/State pursuant to CAATSA statutory timelines

Long term

Ongoing sanctions enforcement; integration with existing national emergency frameworks from EOs 13660 and 13694

Risks & tensions

EO contains no internal deadlines; all timing depends on discretionary determinations by President/Secretaries under CAATSA/UFSA statutes
Vague delegation structure creates uncertainty about which sanctions apply to which designations (CAATSA section 235 vs. UFSA section 4(c) menus)
Potential tension between sanctions mandate and humanitarian exception for loans relieving human suffering (Section 1(a)(i))
Retroactive override of existing contracts and licenses may create legal challenges (Sections 1(c), 2(b), 3(c), 4(b))