US Expands Sanctioning Authority under Executive Order 14024

On 31 March 2022, the US Government made a determination under Executive Order 14024 of April 15 2021 to the effect that sanctions may be imposed on any person operating in the marine, aerospace and electronics sectors of the Russian Federation economy.

This determination is made in accordance with powers under section l(a)(i) of E.O. 14024. It means that sanctions can be imposed on any individual or entity determined to operate or who have operated in any of those sectors. This action builds on previous determinations that were made with respect to the financial services, technology, and defence and related materiel sectors of the Russian Federation economy. This development represents a heightened risk for persons who continue to engage with the marine sector of the Russian economy, although it remains to be seen to what extent these new powers will be exercised by the US Government, and in particular which particular activities involving Russia’s marine sector might be targeted.