Legal authority
Executive Order 13662 (2014)
Executive Order 13662 is a United States emergency authority issued on 20 March 2014 concerning Russia's actions in Ukraine. It authorises property blocking against persons determined to operate in sectors of the Russian economy selected by the Treasury Secretary. OFAC also used delegated authority under the order to issue four directives imposing narrower transaction restrictions on persons identified on the Sectoral Sanctions Identifications (SSI) List.
Two forms of action
The order's text authorises blocking. A person designated as blocked under Executive Order 13662 is added to the Specially Designated Nationals and Blocked Persons List. United States persons generally must block that person's property and interests in property within US jurisdiction, subject to licences and regulations.
The SSI directives are different. They prohibit defined dealings with identified persons without generally blocking all of their property. Directive 1 concerns specified new debt and equity of financial-sector persons. Directive 2 concerns specified new debt of energy-sector persons. Directive 3 concerns specified new debt of defence and related-materiel persons. Applicable maturities depend on the directive and issue date. For debt issued on or after 28 November 2017, the principal thresholds are longer than 14 days under Directive 1, 60 days under Directive 2 and 30 days under Directive 3.
Directive 4 restricts provision, exportation or re-exportation of specified goods, services other than financial services, and technology supporting certain exploration or production projects involving deepwater, Arctic offshore or shale resources. Amendments required by the Countering America's Adversaries Through Sanctions Act expanded specified project coverage and ownership tests for projects initiated on or after 29 January 2018.
Entity and transaction boundaries
The same legal person can be subject to one or more SSI directives and can separately become an SDN. Its status must be checked on current list data. OFAC's 50 Percent Rule can extend the applicable restriction to entities owned 50 per cent or more in aggregate by listed persons. Control without the required ownership does not automatically trigger that rule, although other prohibitions may apply.
A prohibited SSI transaction is ordinarily rejected rather than blocked unless another blocking authority applies. Existing debt, new debt, equity, ordinary payment terms, derivatives and services require separate analysis. The directives do not impose the European Union's restrictions, which rest on EU law.
Strategic significance and current position
The directive model sought to raise financing and technology costs while avoiding a full freeze on major Russian firms. It created a calibrated form of Sectoral sanctions, then interacted with much broader measures after February 2022. This later escalation does not convert every SSI person into an SDN or attribute every Russia sanction to Executive Order 13662.
The order, directives and SSI List remained operative on 30 July 2026. Current tenors, licences, ownership and overlapping designations require transaction-date review.
Historical versions remain relevant to older instruments and contracts.
See also
Sectoral Sanctions Identifications (SSI) List · Sectoral sanctions · Specially Designated Nationals and Blocked Persons List · Council Regulation 833/2014 (EU) · Executive Order 14024 (2021) · Asset freeze
Sources
- Executive Order 13662, Blocking Property of Additional Persons Contributing to the Situation in Ukraine, 20 March 2014.
- Office of Foreign Assets Control, Ukraine-/Russia-related sanctions, directives and guidance checked 30 July 2026.
- Countering America's Adversaries Through Sanctions Act, Pub. L. 115-44, 131 Stat. 886, 2 August 2017.
- Office of Foreign Assets Control, FAQ 370 and FAQ 572, checked 30 July 2026.
Recommended citation
Cite this entry
Tennant, James J., ed. 'Executive Order 13662 (2014).' The Encyclopedia of Economic Statecraft, version 2.0, last reviewed 30 July 2026. https://jamesjtennant.com/entries/executive-order-13662-2014/.
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