ExecutiveOrdersEO
EO 14065Executive OrderBiden · D

Executive Order 14065

Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to Continued Russian Efforts To Undermine the Sovereignty and Territorial Integrity of Ukraine

This executive order expands a 2014 national emergency to impose sanctions on Russia's newly recognized Donetsk and Luhansk regions of Ukraine. It blocks U.S. investment, trade, and financial transactions with these regions; freezes assets of persons operating there; and suspends U.S. entry of sanctioned noncitizens.

Federal Register Open PDF 87 FR 10293

Impact dates

  1. All prohibitions in Sections 1 and 2 take effect; prior contracts/licenses notwithstanding

Key directives

  • Prohibit new U.S. person investment in DNR/LNR regions (Sec. 1(a)(i))
  • Prohibit import of goods/services/technology from Covered Regions (Sec. 1(a)(ii))
  • Prohibit export/reexport/sale/supply of goods/services/technology to Covered Regions (Sec. 1(a)(iii))
  • Prohibit U.S. person approval/financing/facilitation/guarantee of foreign person transactions that would be prohibited if done by U.S. persons (Sec. 1(a)(iv))
  • Block property of persons operating in Covered Regions, their leaders, or those supporting sanctioned persons (Sec. 2)
  • Suspend entry of noncitizens meeting section 2 criteria, with discretionary waiver by Secretary of State or DHS (Sec. 6)
  • Authorize Treasury to promulgate rules and regulations (Sec. 10)

Who is ordered

Timeline

Immediate

  • Investment, trade, and financial prohibitions take effect upon signing (February 21, 2022)
  • Asset blocking authority activated for Secretary of Treasury determinations
  • Visa and entry suspension takes effect for covered noncitizens

Near term (90d)

  • Treasury/State expected to issue implementing regulations and specific designations
  • Potential expansion of 'Covered Regions' beyond DNR/LNR via Secretary determination

Long term

  • Ongoing sanctions enforcement and compliance monitoring
  • Potential escalation or expansion depending on Russia-Ukraine developments
  • Precedent for geographic sanctions regimes and immigration linkages

Risks & tensions

  • Broad 'Covered Regions' definition allows unilateral expansion by Treasury Secretary without further EO
  • Extraterritorial reach on U.S. persons 'wherever located' creates compliance complexity for multinational firms
  • Immigration sanctions linkage (Sec. 6) creates dual-use pressure but waiver authority provides flexibility
  • No prior notice requirement (Sec. 9) raises due process concerns but is framed as necessity for effectiveness
  • Vague 'materially assisted' standard in Sec. 2(a)(iv) creates uncertainty for third-party service providers
Executive Order 14065: Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to Continued Russian Efforts To Undermine the Sovereignty and Territorial Integrity of Ukraine · Executive Orders