Blocking Property With Respect to Certain Russian Energy Export Pipelines
The order imposes sanctions — blocking all U.S.-accessible property and assets — on any foreign person the Secretary of State identifies under a 2019 law targeting Russian energy export pipelines, and directs related visa and entry restrictions to be enforced.
It expands the national emergency declared against harmful Russian government activities in April 2021, using the same IEEPA and PEESA authorities to add a pipeline-specific sanctions layer atop that existing framework.
What this order does
What it orders
The order directs that all property and interests in property belonging to foreign persons identified by the Secretary of State under the Protecting Europe's Energy Security Act (PEESA) be immediately blocked whenever that property is in the United States or within the control of any U.S. person. It prohibits any U.S. person from making contributions, providing funds or services to, or receiving anything of value from, a blocked person. It also directs the Secretary of State and Secretary of Homeland Security to implement PEESA's visa denial and admission restrictions against those same identified individuals.
The order explicitly carves out transactions for official U.S. government and United Nations business, and preserves PEESA's statutory waiver process — meaning the Secretary of State can issue waivers to exempt specific foreign persons from the sanctions. Actual sanctions attach only after the Secretary of State formally identifies a person in a congressional report under PEESA; the order itself does not name or block any specific individual or entity.
Who it affects
Foreign persons — individuals and entities — involved in Russian energy export pipelines who are identified by the Secretary of State under PEESA reporting requirements. U.S. persons and businesses are also affected, as they are prohibited from transacting with any blocked party.
Why it matters
U.S. persons and companies that interact with sanctioned pipeline operators or contractors could face federal enforcement if they transact with a blocked party. Foreign entities tied to Russian energy pipelines face the prospect of having U.S.-accessible assets frozen once formally identified by the State Department.
What must happen and when
How the order is supposed to work
The sanctions activate in two steps: the Secretary of State identifies a foreign person in a PEESA-mandated congressional report, and property-blocking and travel restrictions then apply automatically. The Secretary of the Treasury, in consultation with State, is authorized to issue implementing rules, regulations, and licenses. Treasury may redelegate those functions internally. A statutory waiver process under PEESA allows the Secretary of State to exempt specific persons. No prior notice to a designated person is required before blocking takes effect, because the order finds that advance notice would allow asset flight.
Actions and deadlines
- Implement PEESA visa denial provisions against identified foreign persons
- Implement PEESA admission and parole restrictions against identified foreign persons
- Promulgate rules and regulations necessary to carry out the order's sanctions provisions