E.O. 14066 - Executive Order on Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine

Date issued: Mar. 08 2022

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TURBOFAC Commentary (859 words)

Notes:

1) BACKGROUND:

This EO is an irregular set of prohibitions, limited to certain imports and new investments, and the facilitation thereof. The two separate prohibitions are discussed in turn. Note that these prohibitions operate independent of prohibitions imposed pursuant to EO 14024, even though the activities prohibited by this EO are prohibited by 587.201(b) of the Russian Harmful Foreign Activities Sanctions Regulations (“All transactions prohibited pursuant to any further Executive orders issued pursuant to the national emergency declared in E.O. 14024 are prohibited pursuant to this part.”) Refer to General Note on the Relationship Between Executive Orders, General Licenses and Sanctions Regulations Issued Pursuant to a Common National Emergency. This means that the GLs at 587.509 and 587.510 (official business) apply. Given this, it is not clear why section 3 appears in the EO...