I seem to have gotten the EOs mixed up and thought they were different. You are correct.
EO 13694 was amended by EO 13757. [1] And section 1.a.ii reads: "any person determined by the Secretary of the Treasury, in consultation with the Attorney General and the Secretary of State, to be responsible for or complicit in..." and 1.a.iii has similar wording.
It requires the Treasury and Attorney General to make a determination on the entities being sanctioned. It does not expand the sanctions beyond the entities that are named. So as it stands I can't see how it would require shutting down the ETH network. Sanctioning a sub group does not mean the sanction applies to the parent group. The sanction means US entities cannot interact with the named entities and nothing more. It does not apply to any parent groups and it does not mean other non US entities cannot interact with it. And I don't think the ETH network would count as a US entity.
If the argument is that they could further sanction the entire ETH network, then I suppose they could do that. But that isn't what this sanction does.
EO 13694 was amended by EO 13757. [1] And section 1.a.ii reads: "any person determined by the Secretary of the Treasury, in consultation with the Attorney General and the Secretary of State, to be responsible for or complicit in..." and 1.a.iii has similar wording.
It requires the Treasury and Attorney General to make a determination on the entities being sanctioned. It does not expand the sanctions beyond the entities that are named. So as it stands I can't see how it would require shutting down the ETH network. Sanctioning a sub group does not mean the sanction applies to the parent group. The sanction means US entities cannot interact with the named entities and nothing more. It does not apply to any parent groups and it does not mean other non US entities cannot interact with it. And I don't think the ETH network would count as a US entity.
If the argument is that they could further sanction the entire ETH network, then I suppose they could do that. But that isn't what this sanction does.
[1] https://home.treasury.gov/system/files/126/E.O.%2013694%2C%2...