Executive Order 14114: Taking Additional Steps With Respect to the Russian Federation's Harmful Activities

What does Executive Order 14114 do?

Treasury could identify covered foreign financial institutions; sanction decisions and import controls required subsequent determinations under the amended framework.

There are two distinct mechanisms. Sections 1–2 amend EO 14024, adding a foreign-financial-institution sanctions route and changing its prior-notice provision. Section 3 amends EO 14068, expanding the types of imports that can be restricted through determinations. An affected bank and an affected shipment therefore require different factual and legal checks. OFAC’s explanation of the two amended orders.

For a qualifying foreign financial institution, Treasury may restrict access to U.S. correspondent or payable-through accounts, or impose property-blocking sanctions. Those are alternative authorized measures following the relevant determination, not an automatic penalty on every foreign bank. OFAC explains the resulting U.S. financial-institution obligations and the separate role of authorizations such as general licenses. Sanctions choices, account closure and blocking.

The covered institution definition is broader than deposit-taking banks, extending to listed financial businesses such as insurers, securities dealers and certain affiliates. It also expressly excludes specified international financial institutions. OFAC’s significance analysis considers the circumstances, including transaction size, frequency, management awareness, sanctioned-party connections and deceptive practices; the FAQ does not supply a universal dollar threshold. Definition, exclusions and significance factors.

Currency alone does not remove the risk. OFAC’s updated guidance says the section 11 targeting authorities apply to transactions in any currency, including qualifying activity denominated in a local currency. Separately, Treasury’s June 12, 2024 interpretation included all persons blocked under EO 14024 in Russia’s military-industrial base. That was Treasury’s implementation of the amended framework, not a change made by EO 14117. Non-dollar transactions; the dated Treasury interpretation.

The import provisions also require attention to product origin and the relevant determination. They authorize restrictions on specified Russian-linked categories even after incorporation or substantial transformation outside Russia; they do not automatically prohibit every third-country product. OFAC distinguishes the existing Russian-origin restrictions from the additional categories that require determinations. Categories and determination requirements.

A concrete example is the December 22, 2023 seafood determination. It covered salmon, cod, pollock and crab meeting the stated Russian production, harvesting-water or vessel conditions, even after processing into another product outside Russia. The text retains exceptions provided by law and OFAC licenses or other authorization. Its effective date was December 22, 2023; that historical instrument is not a substitute for checking the authorizations applicable to a present shipment. Actual seafood determination and exceptions.