EO 14068 immediately prohibited the following transactions and activities as of March 11, 2022:
The importation into the United States of fish, seafood, and preparations thereof, alcoholic beverages, and non-industrial diamonds of “Russian Federation origin”;
The exportation, reexportation, sale, or supply, directly or indirectly, from the U.S. or by a U.S. persons, wherever located, of luxury goods to any person located in Russia (this prohibition ban is covered in more depth below);
The exportation, reexportation, sale, or supply, directly or indirectly from the U.S. or by a U.S. person of S. dollar-denominated banknotes to the “Government of the Russian Federation” or any person located in Russia;
Any approval, financing, facilitation, or guarantee by a U.S. person, wherever located, of a transaction made by a foreign person that would be prohibited under EO 14068 if performed by a U.S. person; and
Any transaction by any person (whether a U.S. person or non-U.S. person) that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions above, as well as any conspiracies engaged in by any persons to violate those prohibitions.
EO 14068 also provides the U.S. Secretary of the Treasury, in consultation with the U.S. Secretary of State, with authority to prohibit new investment into certain sectors of the Russian economy as they may determine on a going-forward basis. Currently, the Secretary of the Treasury and Secretary of State have not prohibited new investment into any sectors of the Russian economy pursuant to EO 14068, however readers should be aware that another recent Executive Order (EO 14066) prohibits new investment into the energy sector of the Russian economy as of March 8, 2022 (as previously reported here).
