II. New Executive Order Targeting the Harmful
Foreign Activities of the Russian Government
On April 15, President Biden signed Executive Order 14024, Blocking Property with Respect to Specified Harmful Foreign
Activities of the Government of the Russian Federation,
declaring a national emergency to deal with certain activities
carried out by the Russian government. The order cites several
examples of such activities, including Russian government efforts
to undermine US and foreign elections, malicious
cyber-enabled activities, employing transnational
corruption to influence foreign governments, targeting
dissidents and journalists abroad, and violating well-established principles of international law, including
respect for the territorial integrity of states.
Executive Order 14024 authorizes the imposition of sanctions
Venezuelan politician Nicolas Maduro
It further clarifies that this list of “foreign adversaries” is to be used only for purposes of the Executive Order, the Interim Rule, and any subsequent rules and not for other purposes. Commerce will periodically review the list and make changes as appropriate.
ICTS Transaction: The Interim Rule enhances the definition of “ICTS Transaction” by identifying the specific categories of transactions that are subject to the Executive Order:
Ongoing activities, such as managed services, data transmission, software updates, repairs, or the platforming or data hosting of applications for consumer download
Any other transaction, the structure of which is designed or intended to evade or circumvent the application of the Executive Order