Behind every OFAC program there lurks an Executive Order, normally defining a national emergency based world events. That Executive Order will start: “I Donald J. Trump …”, “I Barack Obama …”, there are ones still relevant today that start “I Jimmy Carter …”. What they say next is very interesting as it defines what the EO and the ensuing sanctions listing are trying to target in their outcome – drugs, terrorism, human rights abuses, etc.

It is possible to analyse all of the relevant EOs and match all of the listings against their objectives, to see the various drivers of American sanctions.

Supporting Foreign Policy has always been a key OFAC phrase and is used in nearly every EO. Narcotics has long been the program with the most listings, however the EO that supports it also references that Violence and Corruption are targets of the narcotics program.

Other important targets of the sanctions include: the support of democratic processes (including the influence of cyber related crime), human rights abuses, acts of terrorism, and the non-proliferation of weapons of mass destruction.

The president of the time chooses their words very carefully when it comes to writing an Executive Order.

Ofac Influencing Factors

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