Section 1. (a) All property and interests in property
that are in the United States, that hereafter come within the
United States, or that are or hereafter come within the
possession or control of any United States person (including
any foreign branch) of the following persons are blocked and may
not be transferred, paid, exported, withdrawn, or otherwise
dealt in:
(i) the persons listed in the Annex to this order; <--The People on the List
and <------ A very important "and". As I read it folks meeting the following critera are also subject to sanctions.
(ii) persons determined by the Secretary of the
Treasury, in consultation with the Secretary of State:
(A) to be an official of the Government of the
Russian Federation;
(B) to operate in the arms or related materiel
sector in the Russian Federation; <---- Relevant
(C) to be owned or controlled by, or to have
acted or purported to act for or on behalf of,
directly or indirectly:
(1) a senior official of the Government of
the Russian Federation; or
2
(2) a person whose property and interests
in property are blocked pursuant to this
order; or
(D) to have materially assisted, sponsored, or
provided financial, material, or technological
support for, or goods or services to or in
support of:
(1) a senior official of the Government of
the Russian Federation; or
(2) a person whose property and interests
in property are blocked pursuant to this
order.
(b) The prohibitions in subsection (a) of this section
apply except to the extent provided by statutes, or in
regulations, orders, directives, or licenses that may be issued
pursuant to this order, and notwithstanding any contract entered
into or any license or permit granted prior to the effective
date of this order.