Executive Order 14024

Executive Order 14024 (EO 14024) is the US presidential order on which most sanctions against Russia rest: the Office of Foreign Assets Control (OFAC), at the Treasury, hangs most of its Russian designations on it. Signed on April 15, 2021, it targets the "harmful foreign activities" of the Russian government: election interference, malicious cyber activity, corruption, undermining a state's territorial integrity. It was used the same day, when the SolarWinds intrusion was attributed to the SVR (Foreign Intelligence Service of the Russian Federation), to designate IT security firms including Positive Technologies. The order allows blocking any person operating in a sector of the Russian economy that Treasury determines: technology, defense, financial services, aerospace, and several more after February 2022. A sector determination blocks nobody automatically; it signals risk, and OFAC then designates name by name. Since February 2022, most of the thousands of Russian names on the SDN (Specially Designated Nationals) List hang on this order, implemented through the regulations at 31 CFR (Code of Federal Regulations) part 587. On December 22, 2023, EO 14114 amended it to reach foreign financial institutions that conduct or facilitate a significant transaction involving Russia's military-industrial base, even with no US nexus. On June 12, 2024, that base was redefined to cover every person blocked under EO 14024, designated Russian banks included. For an insurer the effect runs on two levels. Screening a Russian payee or a cargo counterparty almost always leads back to this order, and the 50 percent rule carries the block down to subsidiaries. More to the point, a third-country bank that pays a claim or collects a premium may cut the relationship for fear of losing its US dollar correspondent accounts; the risk arrives through the bank, long before the insured is ever designated.