On March 20, 2014, President Obama signed his third executive order in under three weeks imposing sanctions against Russia concerning the situation involving Ukraine. Each executive order has a different focus, with a result being a set of economic sanctions that are focused almost as much on non-state actors (President Putin's friends) as they are at the Government of the Russian Federation ("GRF").
The first executive order ("Ukraine 1") allows the U.S. to block the property of any "person" (in "sanctions regimes" it is important to remember that "person" is defined to mean individuals and entities) active in undermining the democratic processes in Ukraine or threatening its stability or territorial integrity. Neither this EO nor the other two is "self-executing." That is, the Secretary of the Treasury, in consultation with the Secretary of State, must name persons whose assets will be blocked. This occurred on March 17, when Treasury named four individuals. Each has been involved in fostering separation of the Crimea from the Ukraine.
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