# Sanctions Designation Pipeline The structural map behind every sanctions story this vault tracks — the [[International Criminal Court]] designations under [[Executive Order 14203]], the [[Global Magnitsky Act]] listings, the terrorist designations that became the predicate for the January 2026 capture of [[Nicolás Maduro]], and the [[Russia and Iran Oil Sanctions Waivers 2026]] that switched two of the largest programs off for a month. The single fact that organizes it: **almost no one is sanctioned by a statute.** Congress wrote the switch (the [[National Emergencies Act]]) and the power the switch turns on (the [[International Emergency Economic Powers Act]]); everything after that — who is nominated, what evidence counts, who signs, who gets off — is an executive process run mostly inside one Treasury office, the [[Office of Foreign Assets Control]], with a review posture in the courts that is close to nonexistent. This map follows one designation end to end: the emergency declaration that makes the authority available, the menu of statutes and orders the designation can rest on, the interagency nomination and the evidentiary memo, the signature and the listing, the automatic reach of the 50 percent rule and the correspondent-banking spillover onto parties never named, the licensing layer where policy actually flexes, the delisting petition, and the two judicial routes that almost never disturb a listing. The parallel State Department track — the Foreign Terrorist Organization designation, which converts a sanctions problem into a criminal one — runs alongside because the 2025–26 practice has fused the two. No officeholders appear inside the fence: the process is evergreen and the names are the current-events layer, carried in the Notes. Sibling maps: [[Emergency Powers Crosswalk]] shows the statute-by-statute menu a declaration unlocks, of which IEEPA is one row; [[How an Executive Order Is Issued and Challenged]] shows how the declaring instrument itself is made; [[Special Counsel Appointment and Removal Flow]] is the other map in this series built around a process that exists mostly as executive self-regulation. Parent hub: [[Federal Agencies Hub]]. > [!note] How to read this chart > `──▶` = the main path · `└─▶` = a branch or off-ramp · `◇` = a decision point · `✕` = the matter ends · `★` = the designation takes effect · `§` = a section of Title 50 U.S.C. unless another title is named · `[]` = a dated 2025–26 practice note or caveat. Bodies inside the fence are institutions, not named individuals. Names inside the fence are plain text; the wikilinks are in the prose, the Notes and the See also. ``` SANCTIONS DESIGNATION PIPELINE │ Legend: ──▶ main path └─▶ branch/off-ramp ◇ decision ✕ ends ★ effective │ § = 50 U.S.C. unless another title is named │ [] = dated 2025-26 practice note or caveat │ ■ 0. THE SWITCH — NO DECLARED EMERGENCY, NO IEEPA │ ├─ National Emergencies Act of 1976 (§§ 1601-1651) │ │ ├─ § 1621 ...... President declares by proclamation or executive order │ │ ├─ § 1631 ...... must SPECIFY which statutory powers are being activated │ │ ├─ § 1641 ...... publish in the Federal Register; report to Congress │ │ ├─ § 1622(d) ... EXPIRES after one year unless renewed by a notice │ │ │ [renewal is a two-paragraph Federal Register notice; │ │ │ the oldest live emergency dates to Nov 14, 1979 (Iran)] │ │ └─ § 1622(b) ... Congress "shall" meet every six months to consider │ │ terminating ──▶ ✕ has never once happened │ ├─ Termination routes │ │ ├─ President ends it ..... by proclamation (also ends every designation │ │ │ made under it — the mass-delisting mechanism) │ │ └─ Congress ends it ...... joint resolution, § 1622(a) — after INS v. │ │ Chadha (1983) this needs the President's │ │ signature or a veto override ──▶ ✕ never done │ └─ Several dozen declared emergencies are live at any time; most of them │ exist for one purpose — to keep a sanctions program switched on. │ │ ◆ THE STRUCTURAL FACT: the "emergency" is not an event, it is a legal │ precondition. A program that has run for forty-six years is still, │ formally, a response to an "unusual and extraordinary threat." │ ■ 1. THE AUTHORITIES — WHAT A DESIGNATION CAN REST ON │ ├─ IEEPA (§§ 1701-1708) ...... the workhorse; block property, prohibit │ │ │ transactions, regulate imports/exports │ │ ├─ requires: threat originating "in whole or substantial part" │ │ │ OUTSIDE the United States, plus a live § 1621 declaration │ │ ├─ § 1702(b) carve-outs: personal communications, informational │ │ │ materials, humanitarian donations (the "Berman amendments") │ │ └─ OUTER LIMIT: Learning Resources v. Trump (SCOTUS, 6-3, Feb 20, 2026) │ │ IEEPA does NOT authorize tariffs. The statute's only │ │ Supreme Court merits loss in forty-nine years — and │ │ it touched trade, not a single designation. │ ├─ Trading with the Enemy Act (1917) ..... wartime only since 1977; │ │ the Cuba embargo is its last tenant │ ├─ Program statutes (each adds a trigger, none replaces the machinery) │ │ ├─ Magnitsky Act (2012) .............. Russia-specific, named-list origin │ │ ├─ Global Magnitsky Act (2016) ....... human-rights abuse & corruption, │ │ │ + EO 13818 (Dec 2017) anywhere; § 1263(d): committee │ │ │ chairs can force a 120-day answer │ │ ├─ CAATSA (2017) ..................... Russia/Iran/N. Korea; SECONDARY │ │ │ sanctions on third parties; the │ │ │ congressional-review lock on │ │ │ lifting Russia sanctions │ │ ├─ Kingpin Act (1999) ................ narcotics traffickers (SDNTK) │ │ └─ Country programs ................... Iran, Syria, N. Korea, Cuba, │ │ Venezuela, Russia/Ukraine, etc. │ ├─ Executive orders as programs (the emergency + the criteria in one text) │ │ ├─ EO 13224 (Sep 2001) .... Specially Designated Global Terrorist (SDGT) │ │ ├─ EO 13818 (Dec 2017) .... Global Magnitsky implementation │ │ └─ EO 14203 (Feb 6, 2025) . sanctions on the International Criminal │ │ Court and those who assist it │ └─ THE PARALLEL STATE DEPARTMENT TRACK (not OFAC, not IEEPA) │ ├─ Foreign Terrorist Organization — INA § 219 (8 U.S.C. § 1189) │ │ ├─ Secretary of State designates, after consulting Treasury & AG │ │ ├─ 7-day advance notice to congressional leadership, then FR notice │ │ └─ consequences no IEEPA listing carries: 18 U.S.C. § 2339B │ │ "material support" FELONY, immigration inadmissibility, │ │ mandatory bank blocking │ └─ § 7031(c) visa bans (annual appropriations rider) — entry ban only, │ no asset freeze; the State Department's own quiet designation tool │ │ ◆ THE FUSION OF 2025-26: the same person is now routinely designated on BOTH │ tracks — SDGT under EO 13224 by Treasury, then FTO by State — and the FTO │ label is what converts a listing into a criminal predicate. See Notes. │ ■ 2. THE NOMINATION — WHO PUTS A NAME FORWARD │ ├─ Sources of a target │ │ ├─ OFAC's own investigators (sanctions targeting officers) │ │ ├─ State (esp. for FTO, Magnitsky, ICC programs) │ │ ├─ DOJ / FBI / DEA (often paired with an indictment or a seizure) │ │ ├─ the intelligence community (classified reporting) │ │ ├─ allied governments (coordinated packages: UK, EU, Canada) │ │ ├─ Congress — Global Magnitsky § 1263(d) letters; the Senate Foreign │ │ │ Relations and Banking chairs and ranking members can compel a │ │ │ written determination within 120 days [a "compel" without a │ │ │ remedy: the answer can be "no"] │ │ └─ NGOs and journalists — Global Magnitsky invites "credible │ │ information" submissions; the origin of most human-rights listings │ ├─ Interagency clearance ..... Treasury (OFAC + Office of Terrorism and │ │ Financial Intelligence) · State · DOJ · │ │ NSC for anything with a diplomatic cost │ └─ ◇ is the target inside a live program's criteria? ─no─▶ ✕ (or: write a │ new EO declaring a new emergency — the EO 14203 route) │ ■ 3. THE EVIDENTIARY MEMO — THE STANDARD IS "REASON TO BELIEVE" │ ├─ OFAC drafts a designation memorandum: identifiers, program criteria, │ │ the evidence, and a legal sufficiency review by Treasury counsel │ ├─ Standard .......... "reason to believe" / "reasonable basis" — NOT │ │ probable cause, NOT preponderance, NOT a hearing │ ├─ Evidence .......... open-source, commercial, law-enforcement, AND │ │ classified reporting the target will never see │ ├─ Notice ............ NONE before designation. The stated rationale: │ │ advance notice lets the target move the assets │ └─ Signature ......... OFAC Director (delegated from the Secretary of the │ Treasury); Secretary of State for FTO and State-run │ programs; the President for a new EO program │ ■ 4. ★ THE DESIGNATION — WHAT HAPPENS AT THE MOMENT OF LISTING │ ├─ SDN List entry published on OFAC's website ──▶ ★ EFFECTIVE IMMEDIATELY │ │ ├─ Federal Register notice follows (days later); the website is the │ │ │ operative instrument │ │ └─ the list runs to many thousands of entries — individuals, entities, │ │ vessels, aircraft, crypto addresses │ ├─ Blocking ........... all property "in the United States" or in the │ │ possession or control of a "U.S. person" is frozen │ │ — not seized; title does not pass (Notes) │ ├─ Reporting .......... U.S. persons must report blocked property to OFAC │ │ within 10 business days (31 C.F.R. § 501.603) │ ├─ THE 50 PERCENT RULE (OFAC guidance, revised Aug 13, 2014) │ │ ├─ any entity owned 50% or more, directly or indirectly, in the │ │ │ AGGREGATE by one or more blocked persons is ITSELF BLOCKED │ │ ├─ automatically — no listing, no notice, no name on any list │ │ └─ "control" without ownership is NOT enough; 49% is not enough; │ │ two SDNs at 25% each IS enough │ ├─ Non-SDN lists (narrower restrictions, same machinery) │ │ ├─ Sectoral Sanctions Identifications (SSI) — debt/equity limits only │ │ ├─ Foreign Sanctions Evaders (FSE) · CAPTA (correspondent-account bans) │ │ ├─ Non-SDN Menu-Based Sanctions (NS-MBS) · Chinese Military-Industrial │ │ └─ the Consolidated Sanctions List aggregates all non-SDN entries │ └─ Penalties for U.S. persons who transact: strict liability civil penalty │ (greater of a statutory cap, inflation-adjusted, or 2x the transaction) │ · willful violation is a 20-year felony (§ 1705) │ ■ 5. THE SPILLOVER — REACHING PARTIES WHO WERE NEVER DESIGNATED │ ├─ Correspondent banking ...... nearly every dollar transaction anywhere │ │ clears through a U.S. bank, which is a │ │ "U.S. person" ──▶ the freeze travels with │ │ the dollar, not with the target │ ├─ De-risking ................. foreign banks drop clients who LOOK like │ │ a sanctions problem; the largest effect of │ │ the system and the least attributable │ ├─ Secondary sanctions ........ the designation of a FOREIGN party for │ │ │ dealing with a designated party │ │ ├─ CAATSA §§ 224-233 (Russia) · Iran: EO 13902 (2020) and the │ │ │ "significant transaction" test │ │ ├─ Dec 2023 EO 14114 amendment: foreign financial institutions │ │ │ facilitating Russia's military-industrial base can be cut off │ │ │ from correspondent accounts outright │ │ └─ no U.S. nexus required — the coercion runs on access to the │ │ dollar, which is why it works and why it is contested │ └─ FTO consequences ........... a bank that processes a payment for an FTO │ has provided "material support"; the │ Anti-Terrorism Act (18 U.S.C. § 2333) │ opens private treble-damages suits │ ■ 6. LICENSES — WHERE THE POLICY ACTUALLY FLEXES │ ├─ General licenses ........ published, self-executing, no application; │ │ │ anyone who fits the terms may transact │ │ └─ [THE WAIVER INSTRUMENT: the March 2026 Russian-oil and Iranian-oil │ │ relief was general licenses, not delistings — nothing left the │ │ SDN list; the transactions were simply authorized for 30 days] │ ├─ Specific licenses ....... application to OFAC; case-by-case; no │ │ statutory deadline; humanitarian, legal-fee, │ │ wind-down, and personal-remittance licenses │ ├─ Statutory carve-outs .... § 1702(b) informational materials and │ │ humanitarian donations; UNSCR 2664-style │ │ humanitarian exceptions written into │ │ programs since Dec 2022 │ └─ ◆ THE STRUCTURAL FACT: a designation is permanent until acted on; a │ license is discretionary, revocable and unreviewed. The politics │ of sanctions in 2025-26 ran through the license desk, not the list. │ ■ 7. GETTING OFF — THE DELISTING PETITION (31 C.F.R. § 501.807) │ ├─ Who may file ......... the listed person or counsel; no standing rule │ ├─ The two arguments │ │ ├─ INSUFFICIENT BASIS — the designation was wrong when made (mistaken │ │ │ identity, the person had already resigned the role) │ │ └─ CHANGE IN CIRCUMSTANCES — the conduct stopped; ownership changed; │ │ the entity dissolved; remedial measures (never sufficient alone) │ ├─ Burden .............. ON THE PETITIONER, to rebut a record it cannot see │ ├─ "Courtesy document" .. OFAC may release the unclassified, non-privileged │ │ portion of the evidentiary memo on request │ │ [formalized in the Reconsideration Portal, │ │ launched July 2026 — Notes] │ ├─ Timeline ............. NONE. No statutory or regulatory deadline for a │ │ decision; petitions have run for years │ ├─ ◇ granted? ─yes─▶ removed from the list; blocked property unblocked │ │ (but never compensated for the freeze) │ │ ─no──▶ written determination; may reapply ONLY with new │ │ arguments or evidence (OFAC FAQ 1261, July 2026) │ ├─ Mass delisting ........ the President terminates the emergency itself │ │ (Burma 2016 · Sudan 2017) — every designation │ │ under it lapses at once, no petition needed │ └─ FTO revocation (8 U.S.C. § 1189(a)(4)-(6)) │ ├─ the organization may petition 2 years after designation │ ├─ State must review every 5 years if no petition is filed │ ├─ Secretary may revoke on changed circumstances or national security │ └─ CONGRESS may block or revoke an FTO designation "by an Act of │ Congress" (§ 1189(a)(5)) — an ordinary bill, so it needs the │ President's signature; the only listing Congress can touch by name │ ■ 8. JUDICIAL REVIEW — TWO DOORS, BOTH NEARLY SHUT │ ├─ OFAC designations ...... Administrative Procedure Act, 5 U.S.C. § 706 │ │ ├─ standard ........... "arbitrary and capricious"; the court reviews │ │ │ the ADMINISTRATIVE RECORD OFAC assembled, │ │ │ including classified material ex parte and │ │ │ in camera │ │ ├─ no discovery, no cross-examination, no jury │ │ ├─ due process ........ POST-deprivation notice and a chance to │ │ │ respond satisfies the Fifth Amendment │ │ │ (Holy Land Foundation v. Ashcroft, D.C. Cir. │ │ │ 2003; Zevallos v. Obama, D.C. Cir. 2015) │ │ └─ foreign persons with no U.S. presence or property have NO │ │ constitutional claim at all (the Verdugo-Urquidez line) │ ├─ FTO designations ........ 8 U.S.C. § 1189(c): D.C. Circuit ONLY, within │ │ 30 days, on the administrative record; the │ │ organization may not contest the underlying │ │ facts in any later criminal prosecution │ └─ ◇ outcome? ─almost always─▶ ✕ AFFIRMED. Reversals are rare enough to │ be named individually — Van Loon v. │ Treasury (5th Cir., Nov 26, 2024: Tornado │ Cash's immutable smart contracts are not │ "property") is the recent one, and it │ turned on the STATUTE's reach, not the │ evidence. The effective forum is │ § 501.807, not a courtroom │ ■ 9. STATE OF THE BOARD — SEPTEMBER 2026 (see Notes for sources and dates) │ ├─ EO 14203 (ICC) ......... seven tranches in eighteen months: eight ICC │ │ judges, a former Prosecutor, two deputy │ │ prosecutors, a UN rapporteur, three NGOs │ │ [constitutional challenge filed S.D.N.Y. │ │ Aug 11, 2026 — pending] │ ├─ Venezuela ............... Cartel de los Soles: SDGT (Treasury, July 2025) │ │ ──▶ FTO (State, effective Nov 24, 2025) │ │ ──▶ narcoterrorism predicate for the │ │ Jan 3, 2026 capture of Nicolás Maduro │ ├─ Russia / Iran ........... March 2026 general licenses suspended oil │ │ sanctions for ~30 days each; no delistings │ ├─ Learning Resources ...... Feb 20, 2026: IEEPA cannot carry tariffs; │ │ every sanctions program left untouched │ └─ Delisting ............... Reconsideration Portal launched July 2026; │ email petitions being phased out ``` ## Notes - **The switch and the power are two different statutes, and the vault's own pages were already treating them as one system.** The [[National Emergencies Act]] (1976) governs *declaring*; the [[International Emergency Economic Powers Act]] (1977) governs *what a declaration lets the President do to property*. A sanctions program is therefore always two instruments stacked: a declaration under § 1621 that names IEEPA among the activated authorities, and the blocking criteria — usually in the same executive order. The [[Emergency Powers Crosswalk]] carries the full menu of statutes a declaration can unlock; IEEPA is the one that does almost all of the sanctions work. - **Congress designed a six-month review and never held it once.** § 1622(b) says each House "shall meet to consider a vote" on terminating every live emergency every six months. There is no recorded instance of the review being held as designed. After *INS v. Chadha* (1983) struck the legislative veto, the termination route in § 1622(a) was rewritten from a concurrent resolution (no presidential signature) to a joint resolution (presidential signature or two-thirds override) — which is the reason Congress has never terminated an emergency over a President's objection. The oldest live declaration is the Iran emergency of November 14, 1979, renewed every year since. - **The evidentiary standard is "reason to believe," and nothing in the pipeline raises it.** OFAC designates on a "reasonable basis"; the petitioner under 31 C.F.R. § 501.807 bears the burden of rebutting a record it cannot fully see; the reviewing court under the APA asks only whether the agency's decision was arbitrary given *that* record, with the classified portions examined ex parte. At no stage does anyone other than the designating office weigh the evidence de novo. *Holy Land Foundation v. Ashcroft* (D.C. Cir. 2003) and *Zevallos v. Obama* (D.C. Cir. 2015) are the anchor cases for the proposition that post-deprivation process satisfies the Fifth Amendment. - **The 50 percent rule is automatic and unlisted.** Under OFAC's revised guidance of August 13, 2014, any entity owned 50 percent or more in the aggregate by one or more blocked persons is itself blocked without ever appearing on a list. The consequence for compliance is that the SDN list is not the universe of blocked parties, only its visible surface; the consequence for the map is that a single designation of an individual can silently block dozens of companies. Control without ownership does not trigger the rule; two designated persons at 25 percent each do. - **Blocking is not forfeiture.** Frozen property stays titled to the designated person; the United States does not take it. Converting blocked assets into forfeited ones requires a separate legal route (civil or criminal forfeiture, or the REPO Act of April 2024 for Russian sovereign assets), which is why "seize the oligarchs' money" and "sanction the oligarchs" are different legal events that the political vocabulary treats as one. - **The waivers of March 2026 were licenses, not delistings.** The [[Russia and Iran Oil Sanctions Waivers 2026]] page records the general licenses that authorized Russian-crude sales through April 11, 2026 and Iranian oil-at-sea sales for 30 days. Nothing left the SDN list; the transactions were authorized around the listings. This is the structural reason a "maximum pressure" posture (see [[Maximum Pressure]]) can be reversed in a morning — the license desk has no notice-and-comment, no deadline and no reviewer. - **The Foreign Terrorist Organization track is the State Department's, and it is what makes a designation criminal.** An OFAC listing freezes property and bars U.S. persons from transacting. An FTO designation under INA § 219 (8 U.S.C. § 1189) additionally makes knowingly providing "material support" a felony under 18 U.S.C. § 2339B, renders members and supporters inadmissible, and opens private treble-damages suits under the Anti-Terrorism Act. The 2025–26 practice fused the tracks: Cartel de los Soles was designated a Specially Designated Global Terrorist by Treasury in July 2025 and a Foreign Terrorist Organization by State effective November 24, 2025 (designation dated November 16; Federal Register notice November 24), the designation naming [[Nicolás Maduro]] as its head. That FTO label is the predicate for the narcoterrorism charges on which Maduro has been held in New York since his capture on January 3, 2026. Tren de Aragua and several Mexican cartels were designated FTOs in February 2025 by the same route. - **The ICC program is an emergency declared against a court.** [[Executive Order 14203]] (February 6, 2025) declared a national emergency with respect to the [[International Criminal Court]] and set blocking criteria for its officials and "those who assist" its investigations of the United States or its allies. The vault's EO page tracks the tranches — Prosecutor [[Karim Khan]] (February 13, 2025), four individuals (June 5), UN Special Rapporteur Francesca Albanese (July 9), four more (August 20), three entities (September 4), two judges (December 18, 2025, three days after they voted to reject Israel's challenge to the Netanyahu and Gallant warrants). Cumulative as of August 11, 2026: eight ICC judges, the former Prosecutor, two deputy prosecutors, Albanese, and three Palestinian NGOs. A constitutional challenge was filed in the Southern District of New York on August 11, 2026 by [[Human Rights Watch]] and three co-plaintiffs. It is pending as of this writing. - **Congress can touch exactly one kind of listing by name, and only by passing a law.** Under 8 U.S.C. § 1189(a)(5) Congress may "block or revoke" an FTO designation by an Act of Congress — which requires the President's signature or a veto override, so it is a bill, not a veto. It holds no comparable route at all over an OFAC listing or a general license, and its route over an emergency declaration (the § 1622(a) joint resolution) is likewise a veto-able ordinary bill after *Chadha*. The [[Global Magnitsky Act]] § 1263(d) letter — committee chairs and ranking members compelling a 120-day written determination on whether a named person meets the criteria — is a right to an *answer*, not to a listing. CAATSA (2017) is the one program where Congress locked the exit: lifting Russia sanctions requires a congressional-review period. - **The only merits loss IEEPA has ever taken in the Supreme Court did not touch a designation.** [[Learning Resources v. Trump]] (February 20, 2026, 6–3) held that IEEPA's power to "regulate … importation" does not include the power to impose tariffs. Every blocking program rests on a different clause (§ 1702(a)(1)(B), "block … any property"), and the Court's reasoning about the taxing power does not reach it. The decision should not be read as a limit on sanctions; it is a limit on trade. - **The delisting process was modernized in July 2026 without changing its substance.** OFAC launched a Reconsideration Portal on or about July 22, 2026 as the preferred channel for § 501.807 petitions, formalized the "courtesy document" request for the unclassified portion of the evidentiary memo, and issued FAQ 1261 (a denied petitioner may reapply only with new arguments or evidence). The burden, the standard, the absence of a deadline, and the classified-record problem are unchanged. Delisting statistics are not published as a series by OFAC; no count is carried here. - **Verified negatives and hedges.** No web-verified count of live national emergencies or of SDN entries is carried in the map; secondary sources put the SDN list above 12,000 entries and the emergency count in the forties, and neither figure is primary-documented. The Cartel de los Soles SDGT date is carried as "July 2025" (the FTO effective date of November 24, 2025 is verified against the State Department release and the Federal Register notice). No officeholder names appear inside the map; the Secretary of the Treasury and the OFAC Director were deliberately not named, because the process does not depend on them and the names would date the map. ## See also - [[Office of Foreign Assets Control]] — the office that runs blocks 2 through 7 - [[International Emergency Economic Powers Act]] · [[National Emergencies Act]] · [[Trading with the Enemy Act]] — the power, the switch, and the wartime ancestor - [[Emergency Powers Crosswalk]] — the full menu of statutes a declaration unlocks - [[Specially Designated Nationals List]] · [[Secondary Sanctions]] · [[Foreign Terrorist Organization]] — the vocabulary this map runs on - [[Magnitsky Act]] · [[Global Magnitsky Act]] · [[Countering America's Adversaries Through Sanctions Act]] — the program statutes - [[Executive Order 14203]] · [[International Criminal Court]] · [[Karim Khan]] · [[Human Rights Watch]] — the ICC program and its challenge - [[Russia and Iran Oil Sanctions Waivers 2026]] · [[Maximum Pressure]] · [[Iran War 2026]] — the license desk in action - [[Nicolás Maduro]] · [[Venezuela]] — the FTO-to-indictment route - [[Learning Resources v. Trump]] · [[Van Loon v. Department of the Treasury]] — the two recent losses, both on the statute's reach rather than the evidence - [[Department of the Treasury]] · [[Department of State]] · [[FinCEN]] — the parent department and the two neighbors - [[How an Executive Order Is Issued and Challenged]] · [[Special Counsel Appointment and Removal Flow]] — sibling maps - [[Federal Agencies Hub]] — parent hub for the map series