United States and United Kingdom Move to Prohibit Russian Oil and Gas Imports

In a much-anticipated action, President Biden announced a prohibition on all Russian oil and gas imports. The United States relies on Russia oil for approximately 8 percent of its needs.

Simultaneously, the United Kingdom announced it will reduce oil and gas imports from Russia over the next nine months.  The UK relies on Russian oil and gas imports for approximately 18 percent of its energy needs.

The latest action is another in step with recent actions by global companies withdrawing from Russia.  So far, BP, Shell, Visa, Mastercard, McDonalds and Coca Cola have announced their intention to withdraw from Russia.

The Biden administration issued a new Executive Order which expands the scope of the national emergency declared in Executive Order 14024, dated April 15, 2021.

Section 1 of the new executive order prohibits the importation from Russia of “crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products.”

The scope of the prohibition, however, extends to “new investment in the energy sector in Russia, and “any approval, financing, facilitation, or guarantee by a United States person.”

The executive order also includes important definitions to guide compliance efforts:

The term “United States person” means any United States citizen, lawful permanent resident, entity organized under the laws of the United States or any jurisdiction within the United States (including foreign branches), or any person in the United States.

The Treasury Department’s Office of Foreign Asset Control issued a new General License 16 under the Russia Sanctions Program authorizing transactions otherwise prohibited pursuant to written contracts or agreements entered into prior to March 8, 2022 until a deadline of April 22, 2022.

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