Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression
The order immediately prohibits all new investment in Russia by U.S. persons and bars the export of certain services to Russia, as part of an expanding set of economic sanctions in response to Russia's continued military aggression.
It invokes emergency economic powers under IEEPA and broadens an existing national emergency declared in April 2021, giving the Treasury Department broad authority to define covered service categories and issue implementing regulations.
What this order does
What it orders
The order prohibits U.S. persons, anywhere in the world, from making new investments in the Russian Federation. It also bans U.S. persons from exporting or supplying any category of services to persons located in Russia, as determined by the Secretary of the Treasury in consultation with the Secretary of State. Additionally, it bars U.S. persons from approving, financing, facilitating, or guaranteeing any foreign-person transaction that would itself be prohibited if conducted by a U.S. person.
The Secretary of the Treasury is authorized to promulgate rules, issue licenses, and use all IEEPA powers necessary to implement the order. All executive departments and agencies must take appropriate measures to enforce it. Standard carve-outs apply for official U.S. government and United Nations business, and prohibitions yield to any regulations or licenses Treasury may issue.
Who it affects
U.S. citizens, lawful permanent residents, and U.S.-organized entities (including their foreign branches) who invest in or provide services to Russia, as well as any person physically located in the United States doing the same. Foreign persons whose transactions are facilitated by U.S. persons are also covered.
Why it matters
U.S. businesses and investors with active or planned Russia operations face an immediate legal prohibition on new investment, with potential IEEPA criminal and civil penalties for violations. The services ban — once Treasury defines covered categories — could affect consulting, legal, financial, and other professional sectors with Russia-linked revenue.
What must happen and when
How the order is supposed to work
The investment prohibition takes effect immediately upon signing. The services prohibition requires the Secretary of the Treasury to first identify covered service categories in consultation with the Secretary of State; until that determination is made, the services ban has no defined scope. Treasury may then issue licenses, rules, and regulations to permit specific transactions. Evasion attempts and conspiracies to violate the order are themselves independently prohibited, extending liability beyond direct actors to those who structure around the rules.
Actions and deadlines
- Determine which categories of services are prohibited for export or supply to Russia
- Promulgate rules, regulations, and licenses to implement the order's prohibitions