Sanctions in the FY2024 Emergency Supplemental Appropriation, P.L. 118-50

Sanctions in the FY2024 Emergency Supplemental Appropriation, P.L. 118-50

May 29, 2024
Sanctions in the FY2024 Emergency Supplemental
Appropriation, P.L. 118-50
Introduction
(IEEPA; 50 U.S.C. §§1701-1706) and Trading with the
President Biden signed P.L. 118-50, Making emergency
Enemy Act (50 U.S.C. §§4301-4341).
supplemental appropriations for the fiscal year ending
Selected Types of Sanctions
September 30, 2024, and for other purposes, into law on
Congress plays a key role in imposing or authorizing U.S.
April 24, 2024. Division D, the 21st Century Peace Through
sanctions in furtherance of foreign policy, national security,
Strength Act, and subsequent divisions of P.L. 118-50
and economic objectives. Such sanctions may take many
consist of provisions to authorize sanctions against Iran and
forms, and provisions in P.L. 118-50 reflect this variety.
Russia, as well as foreign adversaries, drug traffickers,
terrorist groups, and other foreign targets.
Asset-blocking sanctions. Several provisions in P.L. 118-
50 authorize or direct the President to impose sanctions
Sanctions Provisions in Division D and Subsequent
pursuant to IEEPA that block and prohibit transactions in
Divisions of P.L. 118-50
property and interests in property within U.S. jurisdiction of
Targeting Iran
a designated foreign person. Some provisions apply IEEPA-
 Division J, Stop Harboring Iranian Petroleum (SHIP) Act
based asset-blocking sanctions to new or more specific
 Division K, Fight and Combat Rampant Iranian Missile
categories of foreign persons. These provisions direct the
Exports (CRIME) Act
President (or an agency head, as applicable) to determine
 Division L, Mahsa Amini Human rights and Security
which specific persons to sanction.
Accountability (MAHSA) Act
• Section 3103 of Division E targets foreign persons
 Division R, Holding Iranian Leaders Accountable Act
linked to fentanyl trafficking (including precursors or
 Division S, Iran-China Energy Sanctions Act of 2023
related opioids) or transnational criminal organizations
Targeting Russia
involved in fentanyl trafficking.
 Division F, Rebuilding Economic Prosperity and Opportunity
(REPO) for Ukrainians Act
• Section 3 of Division J targets foreign persons who own

or operate a foreign port, vessel, or refinery linked to the
Section 1 of Division G, on “sanctions to harmonize with
allied sanctions” related to Russia
transportation of or significant transactions in Iranian
Targeting foreign adversaries
petroleum.
 Division H, Protecting Americans from Foreign Adversary
• Section 5 of Division K targets foreign persons linked
Control ed Applications Act
to the proliferation of Iranian missiles.
 Division I, Protecting Americans’ Data from Foreign
• Section 3 of Division M targets foreign persons who
Adversaries Act of 2024
provide support to or enable acts of terrorism or engage
Targeting drug traffickers
in a significant transaction with a senior member of
 Division E, Fentanyl Eradication and Narcotics Deterrence
Hamas, Palestinian Islamic Jihad (PIJ), Al-Aqsa Martyrs
(FEND) Off Fentanyl Act
Brigade, Lion’s Den, or any foreign terrorist
 Division P, Il icit Captagon Trafficking Suppression Act of
organization that provides support to those four groups
2023
or any affiliate or successor of such groups.
Targeting terrorist groups
• Section 3 of Division O targets foreign persons linked
 Division M, Hamas and Other Palestinian Terrorist Groups
to PIJ under Sanctioning the Use of Civilians as
International Financing Prevention Act
Defenseless Shields Act (P.L. 115-348, as amended; 50
 Division N, No Technology for Terror Act
U.S.C. §1701 note).
 Section 3 of Division O, Strengthening Tools to Counter the
Use of Human Shields Act
• Section 5 of Division O targets foreign persons linked

to certain significant cyber-enabled activities and
Division Q, End Financing for Hamas and State Sponsors of
Terrorism Act
requires the Secretary of State to respond to requests by
Other targets
the chair and ranking member of certain congressional
committees regarding whether specific foreign persons
 Section 5 of Division O, on “asymmetric and malicious cyber
activities”
have engaged in sanctionable activity.

•
Section 6 of Division O, on threats against U.S. officials
Section 6 of Division O targets foreign persons linked
to threats of violence against any current or former U.S.
Section 3111 of P.L. 118-50 also establishes a 10-year
government officials.
statute of limitations for violations of sanctions imposed
under the International Emergency Economic Powers Act
https://crsreports.congress.gov

Sanctions in the FY2024 Emergency Supplemental Appropriation, P.L. 118-50
• Section 4 of Division P targets foreign persons linked to frequency, or nature of the transaction, (1) Chinese
the production and proliferation of Captagon.
financial institutions involved in the purchase of petroleum
or petroleum products from Iran and (2) foreign financial
Travel bans. Most IEEPA-based asset-blocking sanctions
institutions involved in the purchase of Iranian unmanned
in P.L. 118-50 also include restrictions on U.S. entry and
aerial vehicles.
U.S. visas, pursuant to the Immigration and Nationality Act
(8 U.S.C. §§1101 et seq.). Division J directs the President
Conditions on the release of blocked or immobilized
to impose U.S. visa restrictions on certain sanctioned
assets and authority to seize such assets. Section 103 of
individuals’ family members who “demonstrably benefit
Division F prohibits the release of blocked or immobilized
from such [sanctionable] activity.” Division K directs the
Russian sovereign assets, except as authorized, until
President to impose U.S. visa restrictions on adult family
hostilities between Russia and Ukraine end and Ukraine is
members of a sanctioned individual.
compensated “for harms resulting from the invasion.”
Section 104 authorizes the President to seize, confiscate,
U.S. foreign assistance restrictions. Section 4 of Division
transfer, or vest “any Russian aggressor state sovereign
M directs the President to impose certain measures against
assets” subject to U.S. jurisdiction for the purpose of
foreign state sponsors of acts of international terrorism, as
transferring such funds to a Ukraine Support Fund.
well as foreign states that support Hamas, PIJ, Al-Aqsa
Martyrs Brigade, the Lion’s Den, or any affiliate or
Application of existing sanctions programs to new
successor organization. These measures include a one-year
categories of foreign persons. Several provisions in P.L.
suspension of U.S. assistance to such foreign states,
118-50 direct the President or Secretary of State to report to
including U.S. opposition to international financial
certain congressional committees on the applicability of
institution decisions to provide a loan or financial or
existing U.S. sanctions programs to new targets—and
technical assistance.
correspondingly authorize or require the imposition of such
sanctions (e.g., §1 of Division G, §6 of Division K, and
Export controls. Two provisions in P.L. 118-50 impose
Division L).
U.S. controls on certain exports. Section 4 of Division M
directs the President to prohibit exports of items on the U.S.
U.S. market restrictions. P.L. 118-50 prohibits or
Munitions List to targeted foreign states. Division N
conditions certain U.S. business activity involving foreign
subjects certain foreign-produced items destined for Iran (or
adversary countries (North Korea, China, Russia, and Iran).
the export of which involves the Government of Iran) to the
Division H addresses certain foreign adversary-controlled
“foreign direct product rule” in U.S. Export Administration
applications, including applications operated by TikTok or
Regulations, pursuant to the Export Control Reform Act of
its parent company ByteDance. Division I prohibits data
2018 (50 U.S.C. §§4801-4852).
brokers that handle personally identifiable sensitive data of
U.S. individuals from conducting business with foreign
U.S. port access restrictions. Among other provisions,
adversary countries and entities controlled by such
Section 3 of Division J authorizes the President to prohibit
adversary countries.
certain foreign vessels linked to movements of Iranian
crude oil or petroleum or petrochemical products from
Implementation Outlook
landing at U.S. ports for up to two years.
The 118th Congress may conduct oversight of the Biden
Administration’s implementation of sanctions provisions in
Domestic financial institution restrictions. Section 3201
P.L. 118-50. Key areas of oversight may focus on the pace
of Division E authorizes the Secretary of the Treasury to
of implementing the act’s mandatory sanctions and whether
impose certain “special” anti-money laundering measures
authorized sanctions are implemented. For example, some
on U.S. financial institutions to guard against foreign
provisions in the act direct the President to issue within a
financial institutions, foreign jurisdictions, classes of
transactions, or types of accounts “of primary money
certain timeframe regulations, instructions, or guidance, as
may be necessary to implement certain sanctions. Many
laundering concern in connection with illicit opioid
trafficking.” These measures include prohibiting or
provisions also include waivers, exceptions, and
exemptions that may narrow the scope of implemented
imposing conditions on certain transmittals of funds and the
sanctions in practice.
opening or maintaining of certain correspondent or payable-
through accounts. Section 4(a)(1) of Division R directs the
Congressional committees and Members of Congress may
Secretary of the Treasury to close accounts linked to certain
track the status of various reports, assessment, strategies,
Iranian political and military figures or terrorist group
notifications, certifications, determinations, and briefings
leadership and to “prohibit the provision of significant
required by the act to be submitted to them by the executive
financial services” to such individuals.
branch. Some provisions require one-time reports; other
reports are due on an annually recurring basis.
Secondary sanctions. Secondary sanctions target third-
party foreign actors for their activity with already-
Over time, Congress may review how the new sanctions
sanctioned persons. One example of such a sanction is in
provisions are affecting targeted actors and U.S. foreign
Division S, which amends an existing secondary sanctions
policy and national security objectives. Some provisions in
provision (§1245(d) of P.L. 115-91; 22 U.S.C. §8513a(d))
P.L. 118-50 contain sunset clauses, which Congress may
that targets foreign financial institutions engaged in any
choose in the future to extend, modify, or revoke. Some
significant financial transaction with the Central Bank of
such provisions may also condition the expiration of
Iran or other sanctioned Iranian financial institutions.
sanctions on the basis of whether certain conditions are met
Division S clarifies the meaning of “significant financial
(e.g., a change in behavior of the sanctions target).
transaction” to include, regardless of the size, number,
https://crsreports.congress.gov

Sanctions in the FY2024 Emergency Supplemental Appropriation, P.L. 118-50

IF12676
Liana W. Rosen, Specialist in International Sanctions and
Financial Crimes

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