Taking Additional Steps With Respect to the Russian Federation's Harmful Activities

This executive order expands U.S. sanctions against Russia by authorizing secondary sanctions on foreign financial institutions that facilitate transactions supporting Russia's military-industrial base, and strengthens import bans on Russian-origin fish, seafood, alcoholic beverages, diamonds, and related products. It amends three existing executive orders (14024, 14068) to close loopholes and enhance enforcement capabilities.

Federal Register Open PDF 88 FR 89271

Impact dates

Date TBD
DHS to prescribe documentation collection rules 'as expeditiously as possible' for subsections (a)(i)(B)-(D) and (c) enforcement
Dec 22, 2023
Import prohibitions on fish, seafood, alcoholic beverages, non-industrial diamonds apply to goods imported on or after this date

Key directives

Authorize secondary sanctions on foreign financial institutions conducting significant transactions for Russian military-industrial base sectors or supplying critical items to Russia
Prohibit opening or condition maintenance of U.S. correspondent/payable-through accounts for sanctioned foreign financial institutions
Block property of sanctioned foreign financial institutions
Eliminate prior notice requirement for blocking determinations under E.O. 14024
Expand import ban to cover products substantially transformed outside Russia containing Russian-origin fish, seafood, diamonds
Authorize determinations on additional products of Russian origin
Require DHS to establish documentation collection rules for enforcement

Who is ordered

Timeline

Immediate

Sanctions authority takes effect upon signing for foreign financial institutions
Import prohibitions on fish, seafood, alcoholic beverages, non-industrial diamonds apply to goods imported on or after December 22, 2023

Near term (90d)

Secretary of Homeland Security to prescribe rules for documentation collection 'as expeditiously as possible'
Potential determinations by Treasury on additional products and diamond subheadings

Long term

Ongoing sanctions enforcement against foreign financial institutions
Expanded import ban coverage as secretaries make determinations on additional products and transformed goods
Structural shift in global trade patterns away from Russian-sourced goods

Risks & tensions

Secondary sanctions on foreign banks risk escalation with allied and neutral countries whose financial institutions maintain Russia ties
Definition of 'military-industrial base' and 'other such sectors' leaves broad discretionary authority to Treasury—uncertainty for compliance
'As expeditiously as possible' for DHS rulemaking is vague; no binding deadline
Substantial transformation loophole closure may disrupt legitimate supply chains and raise WTO concerns
Diamond tracing requirements (B-D) pose significant technical and enforcement challenges