E.O. 14114 amends E.O. 14024 to authorize the imposition of sanctions on foreign financial institutions (FFIs) that have engaged in certain transactions involving Russia’s military-industrial base. Specifically, section 11 of E.O. 14024, as amended, authorizes sanctions on FFIs that have (i) conducted or facilitated any significant transaction or transactions for or on behalf of any person designated pursuant to E.O. 14024 for operating or having operated in the technology, defense and related materiel, construction, aerospace, or manufacturing sectors of the Russian Federation economy or other sectors as may be determined to support Russia’s military-industrial base by the Secretary of the Treasury, in consultation with the Secretary of State; or (ii) conducted or facilitated any significant transaction or transactions, or provided any service, involving Russia’s military-industrial base, including the sale, supply, or transfer, directly or indirectly, to the Russian Federation, of any item or class of items as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State and the Secretary of Commerce. See determination of December 22, 2023 pursuant to subsection 11(a)(ii) of E.O. 14024 (Russia Critical Items Determination) for the list of items determined under the order, as amended.
Subsection 11(b) of E.O. 14024, as amended, authorizes OFAC (i) to prohibit the opening or prohibit or impose strict conditions on the maintenance of correspondent accounts or payable-through accounts in the United States for such FFIs or (ii) to block such FFIs.
For additional information and guidance on the amendment to E.O. 14024, see FAQs 1148, 1149, 1150, 1151, 1152, and 1153.