OFAC EO 14071

Executive Order 14071, signed by President Joseph R. Biden on April 6, 2022, is one of the cornerstone U.S. measures imposed in response to Russia's invasion of Ukraine. Its full title is "Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression." It is administered by the Office of Foreign Assets Control (OFAC) within the U.S. Department of the Treasury.

The order does three principal things:

• Bans new investment in the Russian Federation by U.S. persons, wherever located.
• Prohibits the exportation, reexportation, sale, or supply from the United States, or by a U.S. person, of certain categories of services to any person located in the Russian Federation.
• Bars approval, financing, facilitation, or guarantee by a U.S. person of a transaction by a foreign person that would be prohibited if performed by a U.S. person.

The categories of restricted services have been progressively defined through Treasury determinations. Early determinations covered accounting, trust and corporate formation, and management consulting services (May 8, 2022), followed by quantum computing services (September 15, 2022), and later architecture and engineering services (May 19, 2023). On June 12, 2024, Treasury issued a determination expanding restrictions to cover IT consultancy, IT design and support, and certain cloud-based services for enterprise management and design/manufacturing software, effective September 12, 2024.

EO 14071 works alongside EO 14066 (energy import ban) and EO 14068 (luxury goods and import bans) to form the post-invasion U.S. sanctions architecture against Russia. OFAC has issued numerous general licenses under EO 14071 to authorize wind-down activity, humanitarian transactions, telecommunications, and journalism. Violations carry civil penalties under the International Emergency Economic Powers Act (IEEPA) and potential criminal liability.