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Director of National Intelligence (“DNI”)

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On September 12, 2018, President Trump issued a new Executive Order, “Imposing Certain Sanctions in the Event of Foreign Interference in a United States Election” (the “Order”). The Order authorizes the designation as Specially Designated Nationals (“SDNs”) of parties that engage in foreign interference in US elections. While the Order provides the authorization and criteria for such designations, it does not designate any additional parties as SDNs at this time. The Order also requires additional review of the nature and extent of any foreign interference in each US federal election, including the upcoming midterm Congressional elections. Although it is not targeting any particular country or government, the Order comes as the US Congress debates additional sanctions on Russia’s largest banks and energy companies and the purchase of Russian sovereign debt in response to alleged Russian interference in the 2016 US elections.