ExecutiveOrdersEO
EO 14066Executive OrderBiden · D

Executive Order 14066

Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts To Undermine the Sovereignty and Territorial Integrity of Ukraine

This executive order bans U.S. imports of Russian oil, petroleum products, liquefied natural gas, and coal, and prohibits new U.S. investment in Russia's energy sector. It also blocks U.S. persons from facilitating foreign transactions that would violate these prohibitions, expanding sanctions in response to Russia's invasion of Ukraine.

Federal Register Open PDF 87 FR 13625

Impact dates

  1. Import ban and investment prohibitions take effect

Key directives

  • Prohibit importation of Russian crude oil, petroleum, petroleum fuels and products, LNG, coal, and coal products
  • Prohibit new U.S. person investment in Russian energy sector, regardless of location
  • Prohibit U.S. persons from approving, financing, facilitating, or guaranteeing foreign person transactions that would violate the order
  • Exempt official Federal Government and United Nations business transactions
  • Authorize Treasury Secretary, in consultation with State Secretary, to promulgate implementing regulations and employ IEEPA powers
  • Order effective notwithstanding any prior contract, license, or permit

Who is ordered

Timeline

Immediate

  • Import ban and investment prohibition take effect upon signing (March 8, 2022)
  • Existing contracts and licenses do not override prohibitions

Near term (90d)

  • Treasury Department rulemaking and regulatory implementation
  • Market adjustment to replacement energy sources

Long term

  • Structural shift in U.S. energy import patterns
  • Potential lasting constraints on Russia's energy sector financing and development

Risks & tensions

  • No explicit regulatory deadline specified; Treasury implementation timeline is discretionary
  • Prior contract nullification clause creates legal exposure for U.S. firms with existing Russian energy contracts
  • Secondary sanctions-like mechanism (facilitation prohibition) may create compliance complexity for multinational corporations
  • Energy price inflation risk for U.S. consumers given immediate effective date with no phase-in period
  • IEEPA authority invoked; judicial challenge risk exists though historically limited
Executive Order 14066: Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts To Undermine the Sovereignty and Territorial Integrity of Ukraine · Executive Orders