489. The President has amended E.O. 13694 to cover “misappropriation of information.” What does that term mean? Does that mean that Treasury will impose sanctions related to the publication of information by American whistleblowers or members of the press?

No. This authority does not target American whistleblower activity or constitutionally protected activity. The E.O. defines misappropriation to be the “taking or obtaining by improper means, without permission or consent, or under false pretenses.” Importantly, to be eligible for sanctions under this provision, an individual or entity must not only “misappropriate” information, but it must also do so with the purpose or effect of interfering with or undermining election processes or institutions.