President Biden Bans Russian Oil and Gas Imports Into the U.S.

President Joseph R. Biden signed a new Executive Order ("E.O.") banning the import into the United States of Russian energy products. The new E.O. expands the scope of the prohibitions contained in E.O. 14024 ("Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation") and E.O. 14039 ("Blocking Property With Respect to Certain Russian Energy Export Pipelines") in response to Russia’s further invasion of Ukraine.

The new E.O. prohibits:

• the U.S. importation of Russian Federation energy products, including "crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products";
• any new investment by a U.S. person, wherever located, in the Russian Federation energy sector;
• the "approval, financing, facilitation, or guarantee" by a U.S. person, wherever located, of a transaction by a foreign person that would violate the prohibitions set forth in the E.O. if done by a U.S. person or within the United States;
• "[a]ny transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate" the prohibitions set forth in the E.O.; and
• "any conspiracy formed to violate" the prohibitions set forth in the E.O.