On March 8, 2022, President Joseph Biden signed an Executive Order banning the import into the United States of Russian oil, liquefied natural gas, and coal. The Executive Order bans:

  • The importation into the United States of Russian-origin crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products;
  • New investment in Russia’s energy sector by a U.S. person, wherever located; and,
  • Any approval, financing, facilitation, or guarantee by a U.S. person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited if performed by a U.S. person or within the United States.

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued a related Russia General License (GL) 16, which authorizes until April 22, 2022 certain imports of these oil, LNG and coal products of Russian origin so long as such imports are pursuant to written contracts or written agreements entered prior to March 8, 2022. GL 16 does not authorize entry into new contracts. OFAC also issued several FAQs to aid in the wind-down of deliveries of existing purchases that have already been contracted for.