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

This executive order (EO 14114) significantly expands and tightens the United States’ approach to sanctions on the Russian Federation by building on prior emergency authorities. It does two main things: (1) gives the Treasury Department, in consultation with the State and Commerce Departments, new authority to sanction foreign financial institutions that conduct significant transactions with Russia’s military-industrial base or provide related services; sanctions can include restricting correspondent or payable-through accounts and blocking property in the United States or under U.S. control. (2) broadens import restrictions under EO 14068 to cover a wider range of Russian-origin products—specifically fish and seafood, alcoholic beverages, non-industrial diamonds, and other products the Treasury, in consultation with State, Commerce, and Homeland Security, determines—plus products containing or transiting through Russia. The order also short-circuits the usual need for prior notice before listing certain designated entities and requires agencies to implement the measures swiftly, using the authorities provided by the IEEPA and related statutes. In short, the EO aims to squeeze Russia’s military-industrial base from both financial and trade angles: by hitting foreign banks that facilitate Russian defense-related activity and by expanding prohibited imports from Russia to reduce its revenue streams. It relies on existing emergency powers and directs multiple agencies to act to implement the new rules.