Good question.
(B) to be a current or former government official, or a person acting for or on behalf of such an official, who is responsible for or complicit in, or has directly or indirectly engaged in: (1) corruption, including the misappropriation of state assets, the expropriation of private assets for personal gain, corruption related to government contracts or the extraction of natural resources, or bribery; or (2) the transfer or the facilitation of the transfer of the proceeds of corruption; (C) to be or have been a leader or official of: (1) an entity, including any government entity, that has engaged in, or whose members have engaged in, any of the activities described in subsections (ii)(A), (ii)(B)(1), or (ii)(B)(2) of this section relating to the leader’s or official’s tenure; or (2) an entity whose property and interests in property are blocked pursuant to this order as a result of activities related to the leader’s or official’s tenure; or (D) to have attempted to engage in any of the activities described in subsections (ii)(A), (ii)(B)(1), or (ii)(B)(2) of this section;
That language "to be a current or former government official" is repeated throughout this EO. Whomever wrote it, knew what they were targeting.
