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New Executive Order Expands Sanctions Risk in Russia; Targeting Wide Range of Russian Malign Activities and Sovereign Debt


In this article, Brian Fleming,* Timothy O'Toole, Caroline Watson, Manuel Levitt, and Mary Mikhaeel discuss President Biden's newly issued Executive Order, "Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation" (E.O. 14024). E.O. 14024 significantly expands the categories of Russian persons that can be targeted for sanctions by the U.S., moving well beyond the bounds of the existing Ukraine- and Russia-related sanctions program. The broad coverage of the E.O. includes several categories of actors that can now be targeted for blocking sanctions, including those engaged in malicious cyber-enabled activities, election interference, transnational corruption, and attempting to disrupt the gas or energy supply to certain regions outside of Russia, the authors wrote, adding that the new executive order expands restrictions on Russian sovereign debt, prohibiting U.S. financial institutions from participating in the primary market for ruble- and non-ruble-denominated bonds and loans.

*Former Miller & Chevalier attorney