An important element in that is “any person acting as an agent of or on behalf of a foreign government”
Look at that, in the context of Hunter Biden.
You can use your imagination and see easily that could ensnare media and politicians.
.
The EO grabs a lot of people and orgs. Lots and lots and lots.
Does this look like a “trial” is required?
No, DOJ and Homeland Security DECIDE...
Who runs that?
(a) the Secretary of the Treasury shall review the assessment mandated by section 1(a) and the report mandated by section 1(b), and, in consultation with the Secretary of State, the Attorney General, and the Secretary of Homeland Security, impose all appropriate sanctions pursuant to section 2(a) of this order and any appropriate sanctions described in section 2(b) of this order; and