On June 8, 2021, President Biden signed Executive Order 14033 “Blocking Property and Suspending Entry Into the United States of Certain Persons Contributing to the Destabilizing Situation in the Western Balkans” (“EO 14033“), expanding the sanctions regime related to the Western Balkans.  The White House also issued a fact sheet that details the US administration’s policy goals. US State Secretary Antony Blinken also issued a statement  emphasizing the role that EO 14033 serves in modernizing the Western Balkans sanctions regime. Though the EO is mentioned on its Recent Actions page, as of the time of publication, the US Treasury Department’s Office of Foreign Assets Control has yet to designate a party under EO 14033.

Expanding the Scope of Sanctionable Conduct in the Western Balkans

Whereas prior Executive Orders limited sanctionable conduct to obstructing the implementation of regional peace agreements and diminishing the stability or security of any area in the Western Balkans, EO 14033 expands the sanctions authorities for designations to include persons involved in activities that:

  • threaten the peace, security, stability, or territorial integrity of any area in the Western Balkans,
  • undermine democratic processes or institutions in the Western Balkans,
  • obstruct the implementation of regional peace agreements,
  • lead to serious human rights abuse in the Western Balkans, or
  • relate to corruption.

As a result of designations under EO 14033, “US Persons” (i.e., (i) US citizens and permanent residents, wherever located or employed; (ii) entities organized under the laws of the United States and their non-US branches, including through acts of their employees; and (iii) any individual or entity acting through an employee physically located in the United States, even temporarily) are prohibited from directly or indirectly dealing with or facilitating virtually any transactions with such designated parties as well as any entities 50% or more owned by one or more SDNs.  Any property and interests in property of such parties must also be blocked (or “frozen”) if they come within the United States or the possession or control of a US Person, including but not limited to a US financial institution clearing or otherwise handling US dollar transactions that involve these SDNs.  We anticipate any party added to the Specially Designated Nationals and Blocked Persons List under EO 14033 to be listed under the [BALKANS] tag.  EO 14033 defines the Western Balkans as the Republic of Albania and the territory of the former Socialist Federal Republic of Yugoslavia, which today comprises the modern states of Bosnia and Herzegovina, Croatia, Kosovo, Montenegro, North Macedonia, Serbia, and Slovenia. Notably, EO 14033 adds Albania to the Western Balkans, whereas predecessor EOs did not mention the country.


Mr. McMillan's practice involves compliance counseling; compliance programs; licensing; compliance reviews; internal investigations; voluntary disclosures; administrative enforcement actions; criminal investigations; customs inquiries, audits, detentions, and seizures; and trade-compliance due diligence and post-acquisition integration in mergers and acquisitions. His practice includes matters that implicate the US International Traffic in Arms Regulations (ITAR), US Export Administration Regulations (EAR), US National Industrial Security Program (NISP), the US Committee on Foreign Investment in the United States (CFIUS), and equivalent non-US laws. Mr. McMillan regularly advises on and represents clients in matters involving technology, including its control, protection, accidental disclosure, diversion, or unauthorized collection. Mr. McMillan has extensive experience working with companies in the aerospace and defense industry, as well as companies in the Middle East and other parts of Asia.


Meg's practice involves assisting multinational companies with export compliance related matters, specifically trade sanctions and export control classifications. Additionally, she assists companies with respect to customs laws, anti-boycott laws and other trade regulation issues in the US and abroad. She also helps obtain authorizations from the US government for activities subject to sanctions regulations and US export control regulations, including the Export Administration Regulations and the International Traffic in Arms Regulations. Meg's practice extends to assistance in internal compliance reviews as well as enforcement actions and disclosures necessitated by US government action.


Andrea practices international commercial law with a focus on cross-border transactions including post-acquisition integration IP migrations and technology licensing. She also advises companies on export controls, sanctions, customs and international corporate compliance. Andrea also has an active pro bono practice, including helping organizations with international constitutional matters and victims of domestic abuse.