Monday, January 20
The new president of the United States issued several Executive Orders (EOs) on his first day in office. Two of those EOs had an impact on the U.S. sanctions.
Initial Rescissions of Harmful Executive Orders and Actions which revoked the three following EOs with sanctions or export controls implications:
Executive Order 14022 of April 1, 2021 (Termination of Emergency With Respect to the International Criminal Court);
Executive Order 14115 of February 1, 2024 (Imposing Certain Sanctions on Persons Undermining Peace, Security, and Stability in the West Bank); and
The Presidential Memorandum of January 14, 2025 (Certification of Rescission of Cuba’s Designation as a State Sponsor of Terrorism).
Designating Cartels And Other Organizations As Foreign Terrorist Organizations And Specially Designated Global Terrorists. (Here) This EO mandated the Secretary of States to take further actions within 14 days. This action sparked conversation about the impact of potential designations as FTOs from a sanctions point of view, considering the existing restrictions imposed under the Kingpin Act. This article by María Calderón of Wilson Center discusses this issue.
Tuesday, January 21
There were no major developments on this day.
Wednesday, January 22
The U.S. president issued an executive order that sets in motion a process by which Ansar Allah, also known as the Houthis, will be designated as an FTO again. (Here, and Associated Factsheet)
Thursday, January 23
There were no major developments on this day.
Friday, January 24
OTSI added extra information to explain what happens next if your report is about another person or business (not about yourself, your business, or a business you represent). (Here)
To implement the revocation of EO 14115, "Imposing Certain Sanctions on Persons Undermining Peace, Security, and Stability in the West Bank," OFAC removed the West Bank-Related Sanctions program from its website and removed all persons designated under E.O. 14115 from the SDN List. (Here)
Recommendation for the week
In case you missed this back in November, I recommend reading the Fifth Circuit's ruling on Tornado Cash case where the court said: "Perhaps Congress will . Until [when Congress update IEEPA to target modern technologies like crypto-mixing software], we hold that Tornado Cash’s immutable smart contracts (the lines of privacy-enabling software code) are not the “property” of a foreign national or entity, meaning (1) they cannot be blocked under IEEPA, and (2) OFAC overstepped its congressionally defined authority." (Here)
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