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1,014. Are all energy imports from Russia now prohibited by Executive Order (E.O.) of March 8, 2022, “Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine”?
No, only imports of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products of Russian Federation origin into the United States are prohibited by E.O. of March 8, 2022, “Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine.” Imports of other forms of energy of Russian Federation origin are not prohibited by E.O. of March 8, 2022. In addition, E.O. of March 8, 2022 does not prohibit imports of non-Russian Federation origin, even if such items transit through or depart from the Russian Federation. However, targeted...
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1) Refer generally to comments to EO 14066, and refer in particular to FAQ # 1019. Here it is clear that goods merely transiting Russia does not render them of Russian origin (contrast, e.g., 560.306 of the ITSR). Further limitations on the scope of "Russian Federation origin" are found at FAQ 1019.