On December 22, 2023, when many of us had already started our holiday breaks, President Biden issued Executive Order (EO) 14114, which among other things creates new secondary sanctions risk for foreign financial institutions. For anyone who missed this development or anyone who is simply trying to understand the significance of this EO, we’ve highlighted 10 things we think you should know.

This whitepaper is intended to provide a high-level overview of EO 14114. Given the complexities of sanctions compliance, financial institutions should consult with counsel on specific questions related to the applicability and compliance with EO 14114.