What Is Executive Order 13848: Election Sanctions and Penalties

Executive Order 13848 is a presidential directive signed on September 12, 2018, that declares a national emergency over foreign interference in U.S. elections and authorizes the Treasury Department to impose financial sanctions on foreign actors who try to manipulate election results or undermine public confidence in the vote. It sets up a post-election review process, defines what kind of foreign conduct qualifies as sanctionable interference, and lets the government freeze assets, block transactions, and revoke visas. The underlying national emergency has been renewed every year since 2018 and now runs through at least September 12, 2026.

What Counts as Foreign Interference Under the Order

The order targets actions by foreign governments or people acting on their behalf. To qualify as interference, the conduct has to be covert, fraudulent, deceptive, or unlawful, and it has to be aimed at influencing an election result, altering reported results, or undermining public confidence in election processes or institutions.¹ “Covert” has a specific meaning here: the foreign government’s role is intended to stay hidden or unacknowledged publicly.

That definition does real work in practice. A foreign leader publicly endorsing a candidate at a press conference doesn’t qualify, because nothing is being hidden. A foreign intelligence service secretly funding social media accounts to spread disinformation does. Two main categories of conduct tend to trigger the order. The first is attacks on election infrastructure: unauthorized access to voter registration databases, voting machines, tabulation systems, or the networks that transmit results, along with hacks against campaigns, parties, and candidates.² The second is covert propaganda and disinformation: influence operations, fabricated news stories, or front organizations funded by a foreign government to shape opinion about candidates.

The Free Speech Boundary

The order specifically requires that any framework built to enforce it be “insulated from political bias” and “respect the principles of free speech and open debate.”¹ IEEPA, the statute the order runs on, also bars the President from restricting the import or export of “any information or informational materials” in any format. Congress added that carve-out to protect First Amendment activity.³ Personal communications with no transfer of value, ordinary travel transactions, and humanitarian donations of food, clothing, and medicine are also exempt, though the humanitarian exemption can be overridden in certain conditions.

What Sanctions Look Like

When Treasury’s Office of Foreign Assets Control designates someone under EO 13848, three things happen at once. First, all of the designated person’s property and interests in property inside the United States or held by a U.S. person are frozen. Property is defined broadly to cover bank accounts, securities, real estate, goods, and intangible assets, and blocked property cannot be transferred, withdrawn, or dealt with in any way.⁴ Second, visas can be revoked and entry to the United States denied. Third, U.S. persons are prohibited from conducting any transactions with the designated person, including providing funds, goods, or services for their benefit.

The order reaches beyond the direct perpetrators. Any foreign person who materially assists, sponsors, or provides financial, material, or technological support to a designated party or to the interference activity itself can also be sanctioned.⁵ A foreign bank knowingly processing payments for a sanctioned entity or a technology vendor supplying the tools used in an operation can end up on the list. The order also allows recommendations to prohibit credit transfers between financial institutions that would benefit a designated person.

How Interference Gets Assessed After an Election

The order builds a two-stage review that starts as soon as voting ends. Within 45 days of an election, the Director of National Intelligence has to deliver an assessment identifying any foreign government or agent that acted with the intent of interfering. That assessment goes to the President, the Attorney General, and the Secretaries of State, Treasury, Defense, and Homeland Security.¹

A second 45-day clock then starts. The Attorney General and the Secretary of Homeland Security produce their own report evaluating whether the interference actually affected election or campaign infrastructure, and send it to the President and the Secretaries of State, Treasury, and Defense.⁵ Intelligence identifies what happened; law enforcement assesses how much damage it caused. Sanctions decisions rest on both answers.

Who Has Been Sanctioned So Far

For the first stretch after signing, no one was designated under the order. Treasury’s initial semiannual report confirmed that as of early 2019, no entities or individuals had been sanctioned under EO 13848. That changed with later election cycles. In connection with the 2020 presidential election, Treasury designated six employees and executives of Emennet Pasargad, an Iranian company, for running influence operations targeting U.S. voters. For the 2024 cycle, Treasury designated Masoud Jalili, an operative linked to Iran’s Islamic Revolutionary Guard Corps, for acting on the IRGC’s behalf in election interference activities.⁶ Every designation under the order so far has involved Iranian actors, not the Russian interference that originally prompted its creation.

Penalties for Violating the Sanctions

Because EO 13848 operates under IEEPA, breaking its sanctions carries the same penalties as any IEEPA-based program. Civil penalties can reach the greater of $250,000 or twice the value of the underlying transaction, per violation. Willful criminal violations can bring fines up to $1,000,000, imprisonment up to 20 years, or both.⁷ The exposure isn’t limited to the foreign actors named on the sanctions list. Any U.S. person who knowingly conducts prohibited transactions with a designated party, aids a violation, or conspires to evade the sanctions can be prosecuted.

Is Executive Order 13848 Still in Effect

Yes. National emergencies declared under IEEPA expire automatically each year unless the President renews them within 90 days of the anniversary. EO 13848’s emergency has been renewed every year since 2018, and the most recent renewal, published in the Federal Register on September 3, 2025, extends it through at least September 12, 2026.⁸ The full sanctions framework remains operational, Treasury can still make new designations, and existing asset freezes stay in place. If a future President declined to renew the emergency or revoked the order outright, existing sanctions could be unwound, but blocked assets would still have to go through a formal delisting process before being released.

1
The American Presidency Project. Executive Order 13848 – Imposing Certain Sanctions in the Event of Foreign Interference in a United States Election
2
The White House (Archives). Message to the Congress Continuing the National Emergency With Respect to Foreign Interference in or Undermining Public Confidence in US Elections
3
Office of the Law Revision Counsel. 50 USC 1702 – Presidential Authorities
4
U.S. Department of the Treasury / Office of Foreign Assets Control. What Does OFAC Mean When It Refers to Blocked Property? How Does OFAC Define Property?
5
eCFR. 31 CFR Part 579 – Foreign Interference in US Elections Sanctions Regulations
6
U.S. Department of the Treasury. Treasury Sanctions Iranian Regime Agents Attempting to Interfere in US Elections
7
Office of the Law Revision Counsel. 50 USC 1705 – Penalties
8
Federal Register. Continuation of the National Emergency With Respect to Foreign Interference in or Undermining Public Confidence in United States Elections