On January 15, the U.S. Treasury Department re-designated about 100 Russian companies as SDNs that were previously listed as SDNs and added reference to Executive Order 13662 as a ground for designating these companies.

Starting in 2022, the Russian Harmful Foreign Activities Sanctions (RuHSR) has been the primary US sanctions program against Russia essentially based on Executive Order 14024 (supplemented in December 2023 by a secondary sanctions mechanism against third-country banks). Prior to RuHSR, there was a more vigorous Ukraine/Russia Related Sanctions program, which came into existence in 2014, and Executive Order 13662 was part of that program.

The original Ukraine/Russia Related Sanctions program and its executive orders are governed by CAATSA. This law was passed amid congressional fears that Trump might personally weaken the sanctions against Russia imposed under Obama, and Obama’s executive orders, including 13662, were codified by CAATSA, therefore, those no longer were the acts of a previous president that can be repealed by the next president.

The sanctions imposed under the Ukraine/Russia Related Sanctions regime (including 13662) will be much harder to lift. This applies both to any attempts to revoke the executive order and potential presidential initiatives to lift sanctions imposed on specific persons. In addition to the fact that Executive Order 13662 cannot be repealed by the president because it is codified by CAATSA, this law contains a mechanism for congressional review of any executive branch’s decisions to lift or ease sanctions imposed on specific persons, including those designated under Executive Order 13662.