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1,015. Is there a period for U.S. persons to continue imports 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”?
Through 12:01 eastern daylight time, April 22, 2022, Russia-related General License (GL) 16 authorizes all transactions prohibited by E.O. of March 8, 2022 that are ordinarily incident and necessary to the importation of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products of Russian Federation origin pursuant to written contracts or written agreements entered prior to March 8, 2022. GL 16 does not authorize entry into new contracts.
Additionally, E.O. of March 8, 2022 does not prohibit transactions such as the unwinding of contracts or other business-related activities by U.S. persons to comply with the...
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1) Refer generally to comments to EO 14066 and Russia-related General License 16. GL 16 is a not a standard wind-down GL, but refer generally to Examples of Transactions Deemed to Be, and Not to Be, Within the Scope of the Standard “Wind-Down” and “Maintenance” GLs. As noted in the comments to EO 14066, this FAQ may have implications for the relationship between the import prohibition and the facilitation prohibition, i.e. as it relates to transactions that facilitate the importation into third countries of covered oil products.