¹ Powell, Catherine, Libya: A Multilateral Constitutional Moment?, 106 AJIL 298, 310 (2012 CrossRefGoogle Scholar).

² Kirkpatrick, David D., Named Egypt’s Winner, Islamist Makes History, N.Y. Times, June 24, 2012, at A1 Google Scholar, available at http://www.nytimes.com/2012/06/25/world/middleeast/mohamed-morsi-of-muslim-brotherhood-declared-as-egypts-president.html.

³ Kirkpatrick, David D., Army Ousts Egypt’s President; Morsi is Taken Into Military Custody, N.Y. Times, July 3, 2013, at A1 Google Scholar, available at http://www.nytimes.com/2013/07/04/world/middleeast/egypt.html.

⁴ Consolidated Appropriations Act, 2012, Pub. L. No. 112-74, § 7041(a)(1)(B), 125 Stat. 786 (2011).

⁵ Id. § 7041(a)(1)(B).

⁶ Id. § 7008. Since FY 1986, Congress has included the coup provision in its annual appropriation laws. Sharp, Jeremy M., Cong. Research Serv., R43183, Egypt in Crisis: Issues for Congress 5 (2013)Google Scholar. For a discussion of how the Obama administration interpreted Section 7008 in the context of aid to Mali, see Crook, John R., Contemporary Practice of the United States, 107 AJIL 431, 466–68 (2013)CrossRefGoogle Scholar.

⁷ Sharp, supra note 6, at 5. The vast majority of U.S. aid to Egypt is financed from three accounts: Foreign Military Financing, Economic Support Funds, and International Military Education and Training. Sharp, Jeremy M., Cong. Research Serv., RL33003, Egypt: Background and U.S. Relations 17 (2015)Google Scholar. Egypt also receives several million dollars annually from the Nonproliferation, Antiterrorism, Demining, and Related Programs account and the International Narcotics Control and Law Enforcement account. Id. at 17 n.57.

⁸ Secretary of State Hillary Clinton waived the democratization requirement on March 23, 2012 to release FY2012 assistance to Egypt. U.S. Support for Egypt, U.S. Dep’t of State (Mar. 23, 2012), at http://www.state.gov/r/pa/prs/ps/2012/03/186709.htm. Secretary of State John Kerry waived the democratization requirement on May 10, 2013 to release FY2013 assistance to Egypt. Daily Press Briefing, U.S. Dep’t of State (June 7, 2013), at http://www.state.gov/r/pa/prs/dpb/2013/06/210413.htm#Egypt.

⁹ Daily Press Briefing, U.S. Dep’t of State (July 26, 2013), at http://www.state.gov/r/pa/prs/dpb/2013/07/212484.htm#Egypt.

¹⁰ Id.

¹¹ Id.

¹² Remarks by the President on the Situation in Egypt, The White House (Aug. 15, 2013), at https://www.whitehouse.gov/the-press-office/2013/08/15/remarks-president-situation-egypt.

¹³ Gordon, Michael R. & Landler, Mark, In Crackdown Response, U.S. Temporarily Freezes Some Military Aid to Egypt, N.Y. Times, Oct. 9, 2013, at A11 Google Scholar.

¹⁴ Next Steps on Egypt Policy: Hearing Before the H. Comm. on Foreign Affairs, 113th Cong. 15–16, 21–22 (2013) [hereinafter Next Steps on Egypt Policy ] (statement of Derek Chollet, Assistant Secretary of Defense for International Security, U.S. Department of Defense & statement of Alina Romanowski, Deputy Assistant Administrator, Bureau for the Middle East, U.S. Agency for International Development).

¹⁵ Daily Press Briefing, U.S. Dep’t of State (Oct. 10, 2013), at http://www.state.gov/r/pa/prs/dpb/2013/10/215296.htm; see also Background Briefing by Senior Administration Officials on U.S. Assistance to Egypt, U.S. Dep’t of State (Oct. 9, 2013), at http://www.state.gov/r/pa/prs/ps/2013/10/215262.htm (“[I]t amounts to—and again, depending on how you do your calculations over what time period—hundreds of millions of dollars and some high-profile military systems that will not be delivered until there’s progress towards the inclusive democracy that we want to see.”).

¹⁶ Next Steps on Egypt Policy, supra note 14, at 44 (statement of Elizabeth Jones).

¹⁷ Remarks with Egyptian Foreign Minister Nabil Fahmy, U.S. Dep’t of State (Nov. 3, 2013), at http://www. state.gov/secretary/remarks/2013/11/216220.htm.

¹⁸ Next Steps on Egypt Policy, supra note 14, at 44 (statement of Elizabeth Jones).

¹⁹ Id. at 44–45.

²⁰ Consolidated Appropriations Act, 2014, Pub. L. No. 113-76, § 7401(a), 128 Stat. 5, 522–24 (2014).

²¹ Id. § 7041(a)(6).

²² Id. § 7041(a)(1–6).

²³ Id. § 7041(a)(5).

²⁴ Id. § 7041(a)(6).

²⁵ Id. § 7041(a)(6)(A).

²⁶ Id. § 7401(a)(6)(B).

²⁷ Id. § 7401(a)(2–3).

²⁸ Readout of Secretary of Defense Chuck Hagel’s Call with Egyptian Minister of Defense Col. General Sedki Sobhy, U.S. Dep’t of Defense (Apr. 22, 2014), at http://archive.defense.gov/Releases/Release.aspx?ReleaseId=16660.

²⁹ Jen Psaki Daily Press Briefing, U.S. Dep’t of State (Apr. 23, 2014), at http://www.state.gov/r/pa/prs/dpb/2014/04/225092.htm [hereinafter Psaki April 23 Briefing].

³⁰ Id. Although the administration stated in October 2013 that it would continue funding for certain human itarian programs in Egypt, the April 23 announcement was the first time that the administration released any of the $1.5 billion that Congress allocated to Egypt in 2014. U.S. Aid to Egypt, U.S. Dep’t of State (Apr. 24, 2014), at http://www.state.gov/r/pa/prs/ps/2014/04/225147.htm.

³¹ Psaki April 23 Briefing, supra note 29. In order to partially restore aid, the administration also certified, as required by Congress, that Egypt was sustaining its strategic relationship with the United States and maintaining its obligations under the Israel-Egypt peace accord. Id. ; see Consolidated Appropriations Act, 2014 § 7401(a)(1).

³² Psaki April 23 Briefing, supra note 29.

³³ Id. (spokesperson answering in the affirmative when asked: “You can release any funds within the amount that has been appropriated, provided that they only go for those accepted purposes that are in the law, which I think includes Sinai security, counterterrorism, et cetera?”).

³ Consolidated and Further Continuing Appropriations Act, 2015, Pub. L. No. 113-235, §7041(a)(6)(C), 128 Stat. 2130, 2632–35 (2014).

³⁵ Id. § 7041(a)(6)(A).

³⁶ Readout of the President’s Call with President al-Sisi of Egypt, The White House (Mar. 31, 2015), at https://www.whitehouse.gov/the-press-office/2015/03/31/readout-president-s-call-presidental-sisiegypt [hereinafter Readout of the President’s Call]. The administration announced that it would deliver to Egypt 12 F-16 fighter jets, 20 Harpoon missiles, and the parts necessary to assemble up to 125 M 1A1 Abrams tanks. Baker, Peter, Obama Removes Weapons Freeze Against Egypt, N.Y. Times, Mar. 31, 2015, at A1 Google Scholar.

³⁷ Readout of the President’s Call, supra note 36.

³⁸ Baker, Peter, Obama Removes Weapons Freeze Against Egypt, N.Y. Times, Mar. 31, 2015, at A1 Google Scholar.

³⁹ Memorandum of Justification for Certification Under Section 7041(a)(6)(c) of the Department of State, Foreign Operations, and Related Program Appropriations Act, 2015 (May 12, 2015), available at http://graphics8.nytimes.com/packages/pdf/international/2015/egyptwaiver.pdf.

⁴⁰ Id. at 2–6.

⁴¹ Id. at 1.

⁴² Zengerle, Patricia, Senior U.S. Lawmaker Blocks Aid for Egyptian Military, Reuters (Apr. 29, 2014 Google Scholar), at http://www.reuters.com/article/2014/04/29/us-usa-egypt-military-idUsbrea3S0Ny20140429; Comment of Senator Patrick Leahy, Chairman, State Department and Foreign Operations Subcommittee, On Aid to Egypt, U.S. Senator Patrick Leahy of Vermont (June 24, 2014), at http://www.leahy.senate.gov/press/comment-of-senator-pat-rick-leahy-chairman-state-department-and-foreign-operations-subcommittee-on-aid-to-egypt-.

⁴³ The Questionable Legality of Military Aid to Egypt, N.Y. Times, Aug. 19, 2015, at A22 [hereinafter Questionable Legality ].

⁴⁴ Consolidated and Further Continuing Appropriations Act, 2015, Pub. L. No. 113-235, § 8059(a), 128 Stat. 2130, 2267–68 (2014).

⁴⁵ Questionable Legality, supra note 43.

⁴⁶ U.S. Dep’t of State, Leahy Vetting: Law, Policy, Process, Humanrights.gov (Apr. 15, 2013), at http://www.humanrights.gov/wp-content/uploads/2011/10/leahy-vetting-law-policy-and-process.pdf.

⁴⁷ Id.

¹ Joint Comprehensive Plan of Action, July 14, 2015, at http://www.state.gov/e/eb/tfs/spi/iran/jcpoa/ [hereinafter >JCPOA].

² Iran Nuclear Agreement Review Act of 2015, Pub. L. No. 114-17, 129 Stat. 201 (2015). The House and Senate ultimately did not take action to preclude President Obama from waiving those sanctions, and the agreement will be formally adopted on October 15, 2015. Baker, Peter & Davis, Julie Hirschfeld, Nuclear Deal Sealed, Obama Must Now Make It Work, and Mend Fences, N.Y. Times, Sept. 11, 2015, at A6 Google Scholar. [Editors’ note: These developments in Congress occurred after the cut-off date for this edition of the Cpus, but, for completeness, a reference has been added during production.]

³ S.C. Res. 1737 (Dec. 23, 2006); S.C. Res. 1747 (Mar. 24, 2007); S.C. Res. 1803 (Mar. 3, 2008); S.C. Res. 1929 (June 9, 2010). Daugirdas, Kristina & Mortenson, Julian Davis, Contemporary Practice of the United States, 108 AJIL 94, 109 (2014)Google Scholar.

⁴ U.S. Dep’t of Treasury, Iran: What you Need to Know About U.S. Economic Sanctions (Jan. 23, 2012), available at http://www.treasury.gov/resource-center/sanctions/Programs/Documents/iran.pdf; European Union, Restrictive Measures (Sanctions) in Force (July 31, 2013), available at http://eeas.europa.eu/cfsp/sanctions/docs/measures_en.pdf.

⁵ Daugirdas & Mortenson, supra note 3, at 110.

⁶ Id.

⁷ Daugirdas, Kristina & Mortenson, Julian Davis, Contemporary Practice of the United States, 109 AJIL 407, 408 (2015)CrossRefGoogle Scholar.

⁸ Joint Statement by EU High Representative Frederica Mogherini and Iranian Foreign Minister Javad Zarif European Union (Apr. 2, 2015), at http://www.eeas.europa.eu/statements-eeas/2015/150402_03_en.htm (announcing that Iran and the P5 + 1 had agreed to “key parameters” for the JCPOA, with final details to be negotiated throughout June 2015).

⁹ JCPOA, supra note 1, at 16.

¹⁰ Id. Furthermore, the IAEA announced that it had signed an agreement with Iran that allows the Agency to resolve any outstanding questions related to the possible military dimension of Iran’s previous nuclear programs. IAEA Director General’s Statement and Road-Map for the Clarification of Past and Present Outstanding Issues Regarding Iran’s Nuclear Program, International Atomic Energy Agency (July 14, 2015), at https://www.iaea.org/newscenter/pressreleases/iaea-director-generals-statement-and-road-map-clarification-past-present-outstanding-issues-regarding-irans-nuclear-program.

¹¹ S.C. Res. 2231 (July 20, 2015).

¹² JCPOA, supra note 1, at 16.

¹³ Industries in which EU sanctions will be lifted include Iranian oil, gas, and petrochemicals; shipping, ship building, and transport; financial and banking services; and metal and software. JCPOA, supra note 1, at Annex II, 1–7.

¹⁴ U.S. sanctions waivers related to secondary sanctions against Iran, which are designed to target the activities of non-U.S. persons or entities engaging in transactions with Iran, will take effect. Such waivers of statutory sanctions will permit transactions in certain industries, including finance and banking, energy and petrochemicals, automobiles, metals and software, and shipping. Furthermore, the Department of Treasury will license foreign subsidiaries of U.S. companies to engage in transactions with in Iran similar to those that would be permitted to non-U.S. persons. Finally, a number of individuals and entities that were sanctioned for their involvement in Iran’s nuclear program will be removed from the Department of the Treasury’s sanctions lists (though U.S. persons will continue to be prohibited from dealing with such parties unless authorized by Treasury). JCPOA, supra note 1, at Annex II, 12–15.

¹⁵ See Iranian Transactions Regulations, 31 C.F.R. Part 560 (2011); Iranian Assets Control Regulations, 31 C.F.R. Part 535 (2012); see also Iran Sanctions, U.S. Dep’t of the Treasury, at http://www.treasury.gov/resource-center/sanctions/Programs/pages/iran.aspx (last visited July 31, 2015). U.S. statutory sanctions linked to Iran’s “support for terrorism, human rights abuses, and missile activities will remain in effect and continue to be enforced,” such as those imposed as the result of Section 105 of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, which targeted individuals determined to be responsible for human rights abuses after the June 2009 presidential election in Iran. Dianne E. Rennack, Cong. Research Serv., R 43311, Iran: U.S. Economic Sanctions and the Authority to Lift Restrictions 2–3 (2015), availableat https://fas.org/sgp/crs/mideast/R43311.pdf.

¹⁶ JCPOA, supra note 1, at 16; S.C. Res. 2231, supra note 11, ¶ 20.

¹⁷ JCPOA , supra note 1, at 16.

¹⁸ Id. at 6–7.

¹⁹ Gordon, Michael & Sanger, David, Deal Reached on Iran Nuclear Program; Limits on Fuel Would Lessen with Time, N.Y. Times, July 14, 2015, at A1 Google Scholar, available at http://www.nytimes.com/2015/07/15/world/middleeast/iran-nuclear-deal-is-reached-after-long-negotiations.html?_r=0.

²⁰ JCPOA, supra note 1, at 7.

²¹ JCPOA, supra note 1, at Annex I, 12.

²² Id.

²³ Id. at 7–8.

²⁴ Id. at 23.

²⁵ Id.

²⁶ Id.

²⁷ JCPOA, supra note 1, at 17.

²⁸ Id. Any violation of a Commission decision could trigger re-imposition of international sanctions. If any member believes that JCPOA commitments are not being met, a 35-day dispute resolution process ensues, including referral to the foreign ministers of Iran and the P5 + 1, and the establishment of an Advisory Board to issue a non-binding opinion to the Commission. If these measures do not resolve the issue, any Commission member may refer the issue to the Security Council in a procedure, pursuant to Security Council Resolution 2231, that is described above and could lead to re-imposition of sanctions.

²⁹ S.C Res. 2231, supra note 11, ¶ 11. (“[The Security Council] [d]ecides, acting under Article 41 of the Charter of the United Nations, that, within 30 days of receiving a notification by a JCPOA participant State of an issue that the JCPOA participant State believes constitutes significant non-performance of commitments under the JCPOA, it shall vote on a draft resolution to continue in effect the terminations in paragraph 7 (a) of this resolution, decides further that if, within 10 days of the notification referred to above, no Member of the Security Council has submitted such a draft resolution for a vote, then the President of the Security Council shall submit such a draft resolution and put it to a vote within 30 days of the notification referred to above, and expresses its intention to take into account the views of the States involved in the issue and any opinion on the issue by the Advisory Board established in the JCPOA.”).

³⁰ Id. ¶ 12 (“[The Security Council] [d]ecides, acting under Article 41 of the Charter of the United Nations, that, if the Security Council does not adopt a resolution under paragraph 11 to continue in effect the terminations in paragraph 7 (a), then effective midnight Greenwich Mean Time after the thirtieth day after the notification to the Security Council described in paragraph 11, all of the provisions of resolutions 1696 (2006), 1737(2006), 1747 (2007), 1803 (2008), 1835 (2008), and 1929 (2010) that have been terminated pursuant to paragraph 7 (a) shall apply in the same manner as they applied before the adoption of this resolution, and the measures contained in paragraphs 7, 8 and 16 to 20 of this resolution shall be terminated, unless the Security Council decides otherwise.”).

³¹ Sengupta, Somini, ‘Snapback’ is an Easy Way to Reimpose Iran Penalties, N.Y. Times, July 16, 2015, at A10 Google Scholar, available at http://www.nytimes.com/2015/07/17/world/middleeast/snapback-is-easy-way-to-reimpose-iran-penalties.html?_r=0.

³² Id.

³³ Statement by the President on Iran, The White House (July 14, 2015), at https://www.whitehouse.gov/the-press-office/2015/07/14/statement-president-iran [hereinafter Statement by the President on Iran]. See also Back ground Conference Callon Iran, The White House (July 14, 2015), at https://www.whitehouse.gov/the-press-office/2015/07/14/background-conference-call-iran.

³⁴ Feaver, Peter D. & Lorber, Eric, Do the Iran Deal’s “Snapback” Sanctions Have Teeth?, Foreign Policy (July 21, 2015)Google Scholar, at http://foreignpolicy.com/2015/07/21/do-the-iran-deals-snapback-sanctions-have-teeth.

³⁵ JCPOA, supra note 1, at 13.

³⁶ Id.

³⁷ Id. at 3 (“Successful implementation of this JCPOA will enable Iran to fully enjoy its right to nuclear energy for peaceful purposes under the relevant articles of the nuclear Non-Proliferation Treaty (Npt) in line with its obligations therein, and the Iranian nuclear programme will be treated in the same manner as that of any other non-nuclear-weapon state party to the Npt.”).

³⁸ Klapper, Bradley, Kerry Says Congress Would Not Be Able to Change Terms of Iran Deal, PBS Newshour (Mar. 11, 2015)Google Scholar, at http://www.pbs.org/newshour/rundown/kerry-says-congress-able-change-terms-iran-deal.

³⁹ Jen Psaki, Daily Press Briefing, U.S. Dep’t of State (Mar. 10, 2015), at http://www.state.gov/r/pa/prs/dpb/2015/03/238718.htm.

⁴⁰ Id.

⁴¹ Press Briefing by Press Secretary Josh Earnest, The Whitehouse (Jan. 29, 2015), at https://www.whitehouse.gov/the-press-office/2015/01/29/press-briefing-press-secretary-josh-earnest-12915.

⁴² Letter from Chief of Staff Denis McDonough to Senator Bob Corker, The White House (Mar. 14, 2015), at http://www.pbs.org/newshour/rundown/read-disputed-letters-center-iran-nuclear-pact.

⁴³ See, e.g., Goldsmith, Jack & Lederman, Marty, The Case for the President’s Unilateral Authority to Conclude the Impending Iran Deal is Easy Because It Will (Likely) be a Nonbinding Agreement Under International Law, Lawfare (Mar. 11, 2015)Google Scholar, at https://www.lawfareblog.com/case-presidents-unilateral-authority-conclude-impending-iran-deal-easy-because-IT-will-likely-be. But see Golove, David, Congress Just Gave the President Power to Adopt a Binding Legal Agreement with Iran, Just Security (May 14, 2015)Google Scholar, at https://www.justsecurity.org/23018/congress-gave-president-power-adopt-binding-legal-agreement-iran (arguing that “[i]f the ‘non-binding’ character of the agreement is no more than a diplomatic wink and a nod—a distinction of form without substance for the parties to the agreement—then pursuing this course would arguably constitute an abuse of constitutional process, viz., an illegitimate effort to make an end-run around Congress’s core constitutional powers”).

⁴⁴ Iran Nuclear Agreement Review Act of 2015, S. 615, 114th Cong. § 2 (2015) (as reported by S. Comm. on Foreign Rel., Apr. 14, 2015).

⁴⁵ All Bill Information (Except Text) for H.R. 1191—Iran Nuclear Agreement Review Act of 2015, Congress. Gov, at https://www.congress.gov/bill/114th-congress/house-bill/1191/all-info (last visited July 31, 2015).

⁴⁶ Edwards, Julia, Obama to Veto Bill Letting Congress Weigh in on Iran Deal, Reuters (Feb. 28, 2015)Google Scholar, at http://www.reuters.com/article/2015/03/01/us-iran-nuclear-usa-obama-idUskbn0Lx11320150301.

⁴⁷ Statement by the Press Secretary on H.R. 606, H.R. 651, H.R. 1075, H.R. 1191, S. 1124, The White House (May 22, 2015), at https://www.whitehouse.gov/the-press-office/2015/05/22/statement-press-secretary-hr-606-hr-651-hr-1075-hr-1191-s-1124.

⁴⁸ Iran Nuclear Agreement Review Act of 2015, Pub. L. No. 114-17, § 135(b), 129 Stat. 201 (2015).

⁴⁹ Id. § 135(b)(6)(C). It is not entirely clear which sanctions are included under “statutory sanctions” as INARA does not define the term. INARA does suggest—with the inclusion of language regarding the “sense of Congress”— that there maybe a distinction between sanctions imposed on Iran for nuclear activities and other sanctions imposed on Iran, expressing an expectation from Congress that “United States sanctions on Iran for terrorism, human rights abuses, and ballistic missiles will remain in place under an agreement.” Id. § 135(c), (d)(7).

⁵⁰ Id. § 135(c).

⁵¹ Id. § 135(b)2.

⁵² Statement by the President on Iran, supra note 33; see also supra note 2.

⁵³ Sec’y of State John Kerry, Opening Remarks Before the Senate Foreign Relations Committee, U.S. Dep’t of State (July 23, 2015), at http://www.state.gov/secretary/remarks/2015/07/245221.htm.

¹ Statement by the President on Executive Order “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities”, The White House (Apr. 1, 2015), at https://www.whitehouse.gov/the-press-office/2015/04/01/statement-president-executive-order-blocking-property-certain-persons-en.

² Letter—”Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities”, The White House (Apr. 1, 2015), at https://www.whitehouse.gov/the-press-office/2015/04/01/letter-block-ing-property-certain-persons-engaging-significant-malicious- [hereinafter Letter]; see also Exec. Order No. 13,694, 80 Fed. Reg. 18,077 (Apr. 2, 2015).

³ Letter, supra note 2; see also Exec. Order No. 13,694, 80 Fed. Reg. at 18,077–78.

⁴ Exec. Order No. 13,694, 80 Fed. Reg. at 18,077. For other examples of geographically open-ended states of emergency see Murphy, Sean D., Contemporary Practice of the United States 96 AJIL 237, 241 (2002)Google Scholar (declaration of emergency relating to international terrorism in Executive Order 13,224) and Crook, John R., Contemporary Practice of the United States, 105 AJIL 709, 709 (2011)Google Scholar (declaration of emergency relating to transnational organized crime).

⁵ See International Emergency Economic Powers Act of 1977, 50 U.S.C. §§ 1701–02 (2012).

⁶ Exec. Order No. 13,694, 80 Fed. Reg. at 18,079.

⁷ FAQ 444, OFAC FAQS: Other Sanctions Programs, U.S. Dep’t of the Treasury, at http://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_other.aspx#cyber (last visited July 18, 2015) [hereinafter Of ACFAQs ].

⁸ On-the-Record Press Call on the President’s Executive Order, “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities”, The White House(Apr. 1, 2015), at https://www.whitehouse. gov/the-press-office/2015/04/01/record-press-call-president-s-executive-order-blocking-property-certain- [hereinafter Press Call ].

⁹ Nakashima, Ellen, U.S. Establishes Sanctions Program to Combat Cyberattacks, Cyberspying, Wash. Post, Apr. 2, 2015 Google Scholar, available at https://www.washingtonpost.com/world/national-security/us-to-establish-sanctions-program-to-combat-cyberattacks-cyberspying/2015/03/31/7f563474-d7dc-11e4-ba28-f2a685dc7f89_story.html.

¹⁰ Obama Signs Order Creating New Cyber Sanctions Program, N.Y. Times, Apr. 1, 2015, available at http://www.nytimes.com/aponline/2015/04/01/us/politics/ap-us-obama-cyber-sanctions-.html? [hereinafter Cyber Sanctions Program].

¹¹ See id. ; see also Nakashima, supra note 9.

¹² See Cyber Sanctions Program, supra note 10; see also Spodak, Cassie, Obama Announces Executive Order on Sanctions Against Hackers, CNN (Apr. 1, 2015)Google Scholar, at http://www.cnn.com/2015/04/01/politics/obama-cyber-hackers-executive-order.

¹³ Press Call, supra note 8 (“[S]peculating how we would have used this tool in the past is very difficult because the circumstances are going to vary, and we didn’t have the benefit of having this tool when we went through the policy discussions.”).

¹⁴ Id.

¹⁵ FAQ 445, OFAC FAQs, supra note 7.

¹⁶ Press Call, supra note 8.

¹⁷ See, e.g., Exec. Order No. 13,687, 80 Fed. Reg. 819, 819 (Jan. 2, 2015) (imposing sanctions related to North Korean cyberattack on Sony Pictures); Exec. Order No. 13,661, 79 Fed. Reg. 15,535, 15,535 (Mar. 16, 2014) (imposing sanctions related to Russian annexation of Crimea).

¹⁸ Press Call, supra note 8. Daniel further noted that the sanctions were focused on “the activity and the harm involved” instead of location because “cyber incidents tend to flow very easily across international boundaries, and... trying to tie that to particular locations just didn’t make sense....” Id.

¹⁹ Id.

²⁰ Id. ; see also Nakashima, supra note 9 (noting that the order “is modeled in part after regimes that have been used... for counterterrorism and counter proliferation purposes”).

²¹ FAQ 447, OFAC FAQs, supra note 7.

²² Id.

²³ See Exec. Order No. 13,694, 80 Fed. Reg. 18,077 (Apr. 2, 2015).

²⁴ Id. at 18,078; Presidential Policy Directive—Critical Infrastructure Security and Resilience, The White House (Feb. 12, 2013), at https://www.whitehouse.gov/the-press-office/2013/02/12/presidential-policy-directive-critical-infrastructure-security-and-resil [hereinafter Presidential Policy Directive]. See also Crook, John R., Contemporary Practice of the United States, 107 AJIL 447, 447–48 (2013)Google Scholar (discussing executive order on critical infra structure sectors issued the same day as PDD 21).

²⁵ The sectors specified in the order are: Chemical, Commercial Facilities, Communications, Critical Manufacturing, Dams, Defense Industrial Base, Emergency Services, Energy, Financial Services, Food and Agriculture, Government Facilities, Healthcare and Public Health, Information Technology, Nuclear Reactors, Materials, and Waste, Transportation Systems, and Water and Wastewater Systems. Presidential Policy Directive, supra note 24.

²⁶ Press Call, supra note 8.

²⁷ Id. Smith asserted that “we have a responsibility to protect the United States from those who exploit our information technologies to threaten our critical infrastructure, our economic health and financial stability, and other core interests.”

²⁸ Mason, Jeff & Shalal, Andrea, U.S. Targets Overseas Cyber Attackers with Sanctions Program, Reuters (Apr. 2, 2015)Google Scholar, at http://www.reuters.com/article/2015/04/02/us-usa-cybersecurity-idUskbn0Ms4Dz20150402.

²⁹ Fox-Brewster, Thomas, Obama Emergency Cyber Sanctions “Another Salvo in War on Legitimate Hackers”, Forbes (Apr. 1, 2015)Google Scholar, at http://www.forbes.com/sites/thomasbrewster/2015/04/01/obama-cyber-sanctions-war-on-legitimate-hackers.

³⁰ See Mason & Shalal, supra note 28. See also Press Call, supra note 8 (“[W]e don’t want to just deter those that are actually with their fingers on the keyboard, but also those that are behind those groups and that are funding those groups and are enabling those groups to carry out their activity.”).

³¹ Obama, Barack, A New Tool Against Cyber Threats, Medium (Apr. 1, 2015)Google Scholar, at https://medium.com/@PresidentObama/a-new-tool-against-cyber-threats-1a30c188bc4; see also Daniel, Michael, Our Latest Tool to Combat Cyber Attacks: What You Need to Know, The White House (Apr. 1, 2015)Google Scholar, at https://www.whitehouse. gov/blog/2015/04/01/our-latest-tool-combat-cyber-attacks-what-you-need-know (claiming that sanctions will only be levied against “the worst of the worst of malicious cyber actors....”).

³² Obama, supra note 31; see also Monaco, Lisa, Expanding Our Ability to Combat Cyber Threats, The White House (Apr. 1, 2015)Google Scholar, at https://www.whitehouse.gov/blog/2015/04/01/expanding-our-ability-combat-cyber-threats (noting that order would not be used to punish “legitimate cybersecurity researchers or innocent victims whose computers are compromised”); Faqs 448–50, of Acfaqs, supra note 7 (discussing intended targets of sanctions under order).

³³ Press Call, supra note 8.

³⁴ Exec. Order 13,649, 80 Fed. Reg. 18,077, 18,078–79 (Apr. 2, 2015).

³⁵ Press Call, supra note 8.

³⁶ See Fox-Brewster, supra note 29.

³⁷ Press Call, supra note 8.

³⁸ Barker, John P., Lee, Ronald D. & McSorley, Tom, New Executive Order Authorizes Sanctions on Yet Unnamed Perpetrators of Malicious Cyber Threats, Arnold & Porter LLP (Apr. 17, 2015)Google Scholar, at http://www.arnoldporter.com/publications.cfm?action=advisory&u=NewExecutiveOrderAuthorizesSanctionsOnYetUnnamedPerpetratorsof MaliciousCyberThreats&id=1258.

³⁹ See, e.g., Issuance of a New North Korea-related Executive Order; North Korea Designations, U.S. Dep’t of the Treasury (Jan. 2, 2015), at http://www.treasury.gov/resource-center/sanctions/Ofac-Enforcement/Pages/20150102.aspx.

⁴⁰ Baker, Stewart, The President’s Sanctions Program for Hackers, Wash. Post, Apr. 1, 2015 Google Scholar, available at https://www.washingtonpost.com/news/volokh-conspiracy/wp/2015/04/01/the-presidents-sanctions-program-for-hackers.

⁴¹ Daniel, supra note 31.

⁴² Press Call, supra note 8.

¹ Statement by the President on Cuba Policy Changes, The White House (Dec. 17, 2014), at https://www.whitehouse. gov/the-press-office/2014/12/17/statement-president-cuba-policy-changes [hereinafter Cuba Policy Changes]; see also Daugirdas, Kristina & Mortenson, Julian Davis, Contemporary Practice of the United States, 109 AJIL 407, 415 (2015)CrossRefGoogle Scholar.

² Cuba Policy Changes, supra note 1.

³ Id.

⁴ Rescission of Cuba as a State Sponsor of Terror, U.S. Dep’t of State (May 29, 2015), at http://www.state.gov/r/pa/prs/ps/2015/05/242986.htm [hereinafter Rescission of Cuba].

⁵ By statute, the President was required to submit a report to Congress forty-five days before the proposed rescission would take effect certifying that the Cuban government has not provided support for any acts of international terrorism in the past six months and has assured the United States that it will not provide support for terrorism in the future. See Export Administration Act of 1979 § 6(j), 50 App. U.S.C. § 2405 (2012); Arms Export Control Act § 40,22 U.S.C.§2780 (2012); Foreign Assistance Act of 1961§620A 22 U.S.C. § 2371 (2012). The State Department noted that “[w]hile the United States has significant concerns and disagreements with a wide range of Cuba’s policies and actions, these fall outside the criteria relevant to the rescission of a State Sponsor of Terrorism designation.” Rescission of Cuba, supra note 4.

⁶ Rescission of Cuba, supra note 4.

⁷ Export Administration Act of 1979 § 6(j), 50 App. U.S.C. § 2405 (2012); see also Cuba: Implementing Rescission of State Sponsor of Terrorism Designation, 80 Fed. Reg. 43,314 (final rule effective July 22, 2015) (to be codified at 15 C.F.R. pts. 734, 736, 740, 742, 746, 748, 750, 758, 772, 774) (amending the Export Administration Regulations to implement the rescission of Cuba’s designation as a State Sponsor of Terror).

⁸ 22 U.S.C. § 2780.

⁹ Id. § 2371.

¹⁰ State Sponsors of Terrorism, U.S. Dep’t of State, at http://www.state.gov/j/ct/list/c14151.htm (last visited July 20, 2015).

¹¹ Statement by the President on the Re-Establishment of Diplomatic Relations with Cuba, The White House (July 1, 2015), at https://www.whitehouse.gov/the-press-office/2015/07/01/statement-president-re-establishment-diplomatic-relations-cuba [hereinafter Diplomatic Relations with Cuba]. The announcement came after the exchange of presidential letters between the U.S. and Cuban Interests Sections declaring mutual intent to re-establish diplomatic relations and re-open embassies on July 20, 2015. Re-Establishment of Diplomatic Relations with Cuba: Fact Sheet, U.S. Dep’t of State (July 6, 2015), at http://www.state.gov/r/pa/prs/ps/2015/07/244623.htm.

¹² Statement on Cuba, U.S. Dep’t of State (July 1, 2015), at http://www.state.gov/secretary/remarks/2015/07/244542.htm.

¹³ Statement by the Press Secretary on the Opening of the Embassy of the United States in Havana, Cuba and the Opening of the Cuban Embassy in Washington, D.C., The White House (July 20, 2015), at https://www.whitehouse.gov/the-press-office/2015/07/20/statement-press-secretary-opening-embassy-united-states-america-havana. See also Diplomatic Relations with Cuba, supra note 11 (“The U.S. Embassy will continue to perform the existing functions of the U.S. Interests Section, including consular services, operation of a political and economic section, implementation of a public diplomacy program, and will continue to promote respect for human rights.”).

¹⁴ Secretary Kerry’s Remarks at Flag Raising Ceremony, U.S. Dep’t of State (Aug. 14, 2015), at http://www. state.gov/secretary/remarks/2015/08/246121.htm [hereinafter Flag Raising Ceremony].

¹⁵ Id.

¹⁶ See, e.g., U.S. Dep’t of the Treasury, Frequently Asked Questions Related to Cuba (May 5, 2015), available at http://www.treasury.gov/resource-center/sanctions/Programs/Documents/cuba_faqs_new.pdf.

¹⁷ Hemlock, Doreen & Satchel, Arlene, At Least Four Florida Companies Approved for Ferry Service to Cuba, Sun Sentinel (May 5, 2015)Google Scholar, at http://www.sun-sentinel.com/business/tourism/fl-havana-ferry-approval-20150505-story.html.

¹⁸ Carnival Corporation Granted U.S. Approval for Travel to Cuba, Fathom Impact Travel (July 7, 2015), at https://www.fathom.org/carnival-corporation-granted-u-s-approval-for-travel-to-cuba.

¹⁹ Governor Cuomo, Jet Blue, Cuba Travel Services Announce Direct Charter Flight From New York to Havana, New York State (May 5, 2015), at https://www.governor.ny.gov/news/governor-cuomo-jetblue-cuba-travel-services-announce-direct-charter-flight-new-york-havana.

²⁰ Kerry, John, Why I’m Going to Havana, U.S. Dep’t of State (Aug. 14, 2015)Google Scholar, at http://www.state.gov/secretary/remarks/2015/08/246124.htm.

²¹ See 22 U.S.C. §§ 6007, 6063, 6064 (2012).

²² Id. § 6007.

²³ Id. §§ 6064, 6065.

²⁴ Id. § 6064.

²⁵ Id. § 6064, 6066.

²⁶ See S. 491, 114th Cong. (2015) (introduced by Democratic Senator Amy Klobuchar); S. 1543, 114th Cong. (2015) (introduced by Republican Senator Jerry Moran).

²⁷ Some of the most outspoken critics are Senators Ted Cruz [R-Tx], Bob Menendez [D-NJ], and Marco Rubio [R-FL]. Senator Menendez stated that Secretary Kerry’s visit to Cuba is “a validation of the Castro regime’s repressive policies.” Menendez Statement on American Embassy Opening in Cuba, Bob Menendez for New Jersey (Aug. 14, 2015), at http://www.menendez.senate.gov/news-and-events/press/menendez-statement-on-american-embassy-opening-in-cuba. And referring to the Senate’s role in confirmation hearings, Rubio has stated, “I will make sure that the embassy you are opening in Havana will not have a U.S. ambassador unless, at the very least, we see real political reforms and progress on human rights, the return to the U.S. of harbored terrorists and fugitives to face justice, and the resolution of outstanding American property claims and judgments against the Cuban government.” Letter from Marco Rubio, United States Senator, to John Kerry, United States Secretary of State (Aug. 10, 2015), available at http://www.rubio.senate.gov/public/index.cfm?a=files.serve&File_id=46755E9E-446D-495D-Addc-294A6Ed2131C

²⁸ Cuba: Implementing Rescission of State Sponsor of Terrorism Designation, supra note 7. Multiple senators and representatives have introduced bills into Congress that try to remove the embargo, but all of the bills have so far stalled in committee. See e.g., S. 491, 114th Congress (2015) (removing all trade restrictions); S. 1543, 114th Congress (2015) (removing all trade restrictions); H.R. 3238, 114th Congress (2015) (removing all trade restrictions).

²⁹ Diplomatic Relations with Cuba, supra note 11 (“I’ve called on Congress to take steps to lift the embargo that prevents Americans from travelling or doing business in Cuba.... After all, why should Washington stand in the way of our own people?”); see also Flag Raising Ceremony, supra note 14 (“We are all aware that notwithstanding President Obama’s new policy, the overall U.S. embargo on trade with Cuba remains in place and can only be lifted by congressional action-a step that we strongly favor.”).

³⁰ Speech by President Raul Castro on Re-Establishing U.S.-CubaRelations, Wash. Post, Dec. 17, 2014, available athttps:// www.washingtonpost.com/world/full-text-speech-by-cuban-president-raul-castro-on-re-establishing-us-cuba-relations/2014/12/17/45bc2f88-8616-11e4-b9b7-b8632ae73d25_story.html.

³¹ Id.

³² Daily Press Briefing, U.S. Dep’t of State (Aug. 18, 2015), at http://www.state.gov/r/pa/prs/dpb/2015/08/246175.htm#Cuba.

³³ Id.

³ Davis, Julie Hirschfeld, As U.S. and Cuba Relations Warm, Property Claim Issue is Revived, N.Y. Times, July 19, 2015, at A10 Google Scholar, available at http://www.nytimes.com/2015/07/20/world/americas/as-us-and-cuba-relations-warm-property-claims-issue-is-revived.html.

¹ Daugirdas, Kristina & Mortenson, Julian Davis, Contemporary Practice of the United States, 108 AJIL 321, 331 (2014)Google Scholar. See generally Gao, Zhiguo & Jia, Bing Bing, The Nine-Dash Line in the South China Sea: History, Status, and Implications, 107 AJIL 98 (2013)Google Scholar. For a map depicting the nine-dash line, see Damrosch, Lori Fisler & Oxman, Bernard H., Editors’ Introduction to Agora: The South China Sea, 107 AJIL 95, 96 (2013)Google Scholar.

² Ashton Carter, Secretary of Defense, Statement at the Iiss Shangri-La Dialogue: “A Regional Security Architecture Where Everyone Rises” (May 30, 2015), available at http://www.defense.gov/Speeches/Speech.aspx?SpeechId=1945.

³ Id.

⁴ Secretary of State Hillary Clinton, Remarks at Press Availability in Hanoi, Vietnam, U.S. Dep’t of State (July 23, 2010), at http://www.state.gov/secretary/20092013clinton/rm/2010/07/145095.htm.

⁵ Daniel R. Russel, Assistant Secretary, Bureau of East Asian and Pacific Affairs, Testimony Before the House Committee on Foreign Affairs Subcommittee on Asia and the Pacific (Feb. 5, 2014), at http://www.state.gov/p/eap/rls/rm/2014/02/221293.htm.

⁶ Carter, supra note 2.

⁷ Watkins, Derek, What China Has Been Building in the South China Sea, N.Y. Times, July 31, 2015 Google Scholar, at http://www.nytimes.com/interactive/2015/07/30/world/asia/what-china-has-been-building-in-the-south-china-sea.html.

⁸ Gao & Jia, supra note 1, at 99–100.

⁹ Id.

¹⁰ Carter, supra note 2.

¹¹ Id.

¹² Remarks at the Fifth Annual South China Sea Conference, U.S. Dep’t of State (July 21, 2015), at http://www.state.gov/p/eap/rls/rm/2015/07/245142.htm (quoting Ass’n of Southeast Asian Nations, Declaration on the Conduct of the Parties in the South China Sea, ¶ 5, Nov. 4, 2002, at http://www.asean.org/asean/external-relations/china/item/declaration-on-the-conduct-of-parties-in-the-south-china-sea).

¹³ Editors’ note: China uses the name “Nansha Islands” instead of “Spartly Islands.”

¹⁴ Foreign Ministry Spokesperson Hua Chunying’s Remarks on US Defense Secretary Carter’s Speech Relating to the Issue of the South China Sea at the Shangri-La Dialogue, Ministry of Foreign Aff. of China (May 30, 2015), at http://www.fmprc.gov.cn/mfa_eng/xwfw_665399/s2510_665401/t1268781.shtml.

¹⁵ See Carter, supra note 2.

¹⁶ Id.

¹⁷ See Intervention at the East Asia Summit, U.S. Dep’t of State (Aug. 6, 2015), at http://www.state.gov/sec-retary/remarks/2015/08/245758.htm.

¹⁸ E.g., Denyer, Simon, Chinese Warnings to U.S. Plane Hint of Rising Stakes over Disputed Islands, Wash. Post, May, 21, 2015 Google Scholar, available at https://www.washingtonpost.com/world/asia_pacific/chinese-warnings-to-us-plane-hint-of-rising-stakes-over-disputed-islands/2015/05/21/381fffd6-8671-420b-b863-57d092ccac2d_story.html; see also South China Sea: China’s Navy Told US Spy Plane Flying over Islands to Leave ‘Eight Times’, Cnn Reports, Abc News (May, 21, 2015), at http://www.abc.net.au/news/2015-05-22/us-spy-plane-in-south-china-sea-warned-to-leave-by-china/6488690 [hereinafter China’s Navy] (“At one stage... a Chinese radio operator said with exasperation: ‘This is the Chinese navy... you go!’... ‘We were just challenged 30 minutes ago and the challenge came from the Chinese navy,’ said Captain Mike Parker, commander of Us surveillance aircraft deployed to Asia. ‘I’m highly confident it came from ashore, this facility here,’ he said, pointing to an early warning radar station on Fiery Cross Reef.” (second ellipsis in original)).

¹⁹ China’s Navy, supra note 17 (“A spokeswoman for the US state department said US planes operated ‘in accordance with international law in disputed areas of the South China Sea’ and would continue to do so ‘consistent with the rights freedoms and lawful uses of the sea.’”). For an overview of the recently adopted Code for Unplanned Encounters at Sea (CUES), see Daugirdas, Kristina & Mortenson, Julian Davis, Contemporary Practice of the United States, 108 AJIL 516, 529 (2014)Google Scholar.

²⁰ FlorCruz, Michelle, Us Navy South China Sea Surveillance Flyover Harmed Bilateral Relations: Beijing Defense Officials, Int’l Bus. Times (July 20, 2015)Google Scholar, at http://www.ibtimes.com/us-navy-south-china-sea-surveillance-flyover-harmed-bilateral-relations-beijing-2015737.

²¹ Foreign Ministry Spokesperson Lu Kang’s Remarks on Issues Relating to China’s Construction Activities on the Nansha Islands and Reefs, Ministry of Foreign Aff. of China (June 16, 2015), at http://www.fmprc.gov.cn/mfa_eng/xwfw_665399/s2510_665401/2535_665405/t1273370.shtml.

²² Wang Yi on the South China Sea Issue at the Asean Regional Forum, Ministry of Foreign Aff. of China (Aug. 6, 2015), at http://www.fmprc.gov.cn/mfa_eng/zxxx_662805/t1287277.shtml.

²³ Id.

²⁴ Id.

²⁵ Id.

¹ Nine Fifa Officials and Five Corporate Executives Indicted for Racketeering Conspiracy and Corruption, U.S. Dep’t of Justice (May 27, 2015), at http://www.justice.gov/opa/pr/nine-fifa-officials-and-five-corporate-executives-indicted-racketeering-conspiracy-and [hereinafter Racketeering Conspiracy and Corruption ].

² Id.

³ Indictment at 113–48, United States v. Webb et. al. (E.D.N.Y. May 20, 2015) (No. 1:15-cr-00252-RJD), available at http://www.justice.gov/opa/file/450211/download (detailing alleged violations of Title 18, U.S.C., Sections 1343, 1349, 1956, 1957, 1962, 1963, and 3551) [hereinafter Indictment U.S. v. Webb].

⁴ Id.

⁵ Id.

⁶ Id. at 133–34.

⁷ Attorney General Loretta E. Lynch Delivers Remarks at Press Conference Announcing Charges Against Nine Fifa Officials and Five Corporate Executives, U.S. Dep’t of Justice (May 27, 2015), at http://www.justice.gov/opa/speech/attorney-general-loretta-e-lynch-delivers-remarks-press-conference-announcing-charges [hereinafter Lynch Delivers Remarks ].

⁸ About FIFA: Who We Are, FIFA, at http://www.fifa.com/about-fifa/who-we-are/index.html (last visited July 15, 2015); see also Indictment U. S. v. Webb, supra note 3, at 1–3.

⁹ FIFA Statutes, April 2015 Edition 6, 17 (2015), available at http://resources.fifa.com/mm/document/affederation/generic/02/58/14/48/2015fifastatutesen_neutral.pdf.

¹⁰ Associations, FIFA, at http://www.fifa.com/associations/ (last visited July 15, 2015).

¹¹ FAQ: Setting the Record Straight, FIFA, at http://www.fifa.com/mm/document/tournament/competition/02/36/32/63/faq_en_neutral.pdf (last visited July 15, 2015).

¹² See Indictment U.S. v. Webb, supra note 3, at 7 (referencing Fifa’s published income statement for the 2007–2010 and 2011–2014financial periods, in which Fifa attributed 83% and 70%of its respective $4.189 billion and $5.718 billion in revenue to the sale of television and marketing rights for upcoming World Cups).

¹³ Racketeering Conspiracy and Corruption, supra note 1.

¹⁴ Indictment U.S. v. Webb, supra note 3, at 31–47.

¹⁵ Id. at 80–86.

¹⁶ Id.

¹⁷ Id. at 81.

¹⁸ Id. at 82.

¹⁹ Id. at 83.

²⁰ Id. at 92–93.

²¹ Id. at 14–22 (listing the defendants, including executives of sports media and marketing businesses headquartered in the United States and abroad; officials of Fifa, continental soccer confederations, and constituent regional and national associations; and intermediaries who allegedly facilitated the distribution of bribes).

²² Id. at 1–14.

²³ E.g., Indictment U.S. v. Webb, supra note 3, at 39–41, 54–59, 106–07 (detailing wire communications between U.S. and foreign financial institutions).

²⁴ Id. at 85, 98, 101.

²⁵ Id. at 61–89.

²⁶ Comment by Foreign Ministry Spokesman Alexander Lukashevich on the arrest of Fifa officials, Ministry of Foreign Aff. of the Russ. Fed’N (May 27, 2015), at http://archive.mid.ru/bdomp/brp_4.nsf/e 78a48070f128a7b43256999005bcbb3/e7d8e10011cedad043257e530039eb92!OpenDocument.

²⁷ Id.

²⁸ Assistant Attorney General Leslie R. Caldwell Delivers Remarks at the 26th Annual Association of Certified Fraud Examiners Global Fraud Conference, U.S. Dep’t of Justice (June 15, 2015), at http://www.justice.gov/opa/speech/assistant-attorney-general-leslie-r-caldwell-delivers-remarks-26th-annual-association.

²⁹ Id.

³⁰ Letter Providing Case Update at 1–2, United States v. Webb et. al., (E.D.N.Y. July 16, 2015) (No. 1:15-cr-00252-Rjd) [hereinafter Letter Providing Case Update], available at http://www.plainsite.org/dockets/2lowqz-vyi/new-york-eastern-district-court/usa-v-webb-et-al; see also Matt Apuzzo et. al., Fifa Officials Arrested on Corruption Charges; Blatter Isn’t Among Them, N.Y. Times, May 26, 2015, at A1, available at http://www.nytimes.com/2015/05/27/sports/soccer/fifa-officials-face-corruption-charges-in-us.html.

³¹ Letter Providing Case Update, supra note 30, at 2; see also Interpol Issues Red Notices for Former Fifa Officials and Executives Wanted by U.S. Authorities, U.S. Dep’t of Justice (June 3, 2015), at http://www.justice.gov/interpol-washington/pr/interpol-issues-red-notices-former-fifa-officials-and-executives-wanted-us.

³² See, e.g., Usa Asks Switzerland to Extradite the Seven Detained Fifa Officials, Fed. Off. of Justice (Switz.) (July 2, 2015), at https://www.bj.admin.ch/bj/en/home/aktuell/news/2015/2015-07-02.html.

³³ Fifa Official Agrees to Extradition to Usa, Fed. Off. of Justice (Switz.) (July 10, 2015), at https://www. bj.admin.ch/bj/en/home/aktuell/news/2015/2015-07-10.html; Remnick, Noah, Jeffrey Webb, Top Fifa Official, Pleads Not Guilty in Corruption Case, N.Y. Times, July 18, 2015 Google Scholar, at SP5, available at http://www.nytimes.com/2015/07/19/sports/soccer/jeffrey-webb-top-fifa-official-pleads-not-guilty-in-corruption-case.html; Argentine Willing to be Extradited to U.S. In Fifa Case, Associated Press (June 10, 2015), at http://www.nytimes.com/aponline/2015/06/10/world/americas/ap-soc-fifa-investigation-burzaco.html; Ruiz, Rebecca R., Argentine Businessman Pleads Not Guilty in Fifa Corruption Case, N.Y. Times, July 31, 2015, at D6Google Scholar, available at http://www.nytimes.com/2015/08/01/sports/soccer/in-fifa-corruption-case-alejandro-burzaco-of-argentina-pleads-not-guilty.html.

³⁴ Majority of Arrested Individuals Contesting Extradition to the Usa, Fed. Off. of Justice (Switz.) (May 27, 2015), at https://www.bj.admin.ch/bj/en/home/aktuell/news/2015/2015-05-271.html; Julio Rocha Agrees to Extradition to Nicaragua, Fed. Off. of Justice (Switz.) (Aug. 14, 2015), at https://www.bj.admin.ch/bj/en/home/aktuell/news/2015/2015-08-14.html; Ruiz, Rebecca R., How the 14 Indicted FIFA Defendants Currently Stand, N.Y. Times, Aug. 8, 2015 Google Scholar, available at http://www.nytimes.com/2015/08/08/sports/soccer/how-14-in-dicted-fifa-officials-currently-stand.html.

³⁵ Nebehay, Stephanie, Swiss Expect to Decide on FIFA Extraditions in September, Reuters (Aug. 25, 2015)Google Scholar, at http://www.reuters.com/article/2015/08/25/soccer-fifa-swiss-idUsl5N11033F20150825.

³⁶ Usa Asks Switzerland to Extradite the Seven Detained FIFA Officials, Fed. Off. of Justice (Switz.) (July 2, 2015), at https://www.bj.admin.ch/bj/en/home/aktuell/news/2015/2015-07-02.html.

³⁷ Haynes, Brad, Executive Charged in FIFA Soccer Probe Now Back in Brazil, Reuters (June 16, 2015)Google Scholar, at http://www.reuters.com/article/2015/06/16/us-soccer-fifa-brazil-extradition-idUSKBN0OW2LX20150616.

³⁸ Lynch Delivers Remarks, supra note 7.

³⁹ Names of the Persons Arrested, Fed. Off. of Justice (Switz.) (May 27, 2015), at https://www.bj.admin.ch/bj/en/home/aktuell/news/2015/2015-05-270.html.

⁴⁰ The Office of the Attorney General of Switzerland Seizes Documents at Fifa, Fed. Council (Switz.) (May 27, 2015), at https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-57391.html.

⁴¹ Id.

⁴² Letter Providing Case Update, supra note 30, at 4.

⁴³ See, e.g., Letter dated 6/30/15 from Manuel Garrido, Member of the Argentine House of Representatives, United States v. Webb et. al. (E.D.N.Y. July 14, 2015) (No. 1:15-cr-00252-RJD). The letter was directed to the wrong judge, but she wrote back and advised Mr. Garrido to contact the U.S. Attorney for the Eastern District of New York for further information.

⁴⁴ Lynch Delivers Remarks, supra note 7.

⁴⁵ Id.

⁴⁶ Id.