On 9 March, US Customs and Border Protection (CBP) issued guidance to implement Part A of the Office of Foreign Assets Control (OFAC) General License No. 16, Authorizing Transactions Related to Certain Imports Prohibited by Executive Order of 8 March 2022 Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine (“GL16“). GL16 expires at 12:01 am Eastern daylight time on 22 April 2022. After 22 April, Executive Order 14066, signed by President Biden on 8 March, prohibits crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products from the Russian Federation from entering the United States.

Through 22 April, filers of entries or admissions to Foreign Trade Zones for shipments of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products of Russian Federation origin will be required to provide to CBP purchase orders and/or executed contracts and/or any other documentation showing when the order and/or contract went into effect. Filers are required to provide this documentation prior to unlading at the US port of entry, and preferably prior to arrival. Documentation should include conveyance information, bill of lading number(s) and entry number(s) or FTZ admission information. CBP will place holds on both unlading and cargo pending verification of the required information. 

Additionally, effective immediately and until further notice, shipments of prohibited Russian petroleum products are not authorized for direct delivery privilege. CBP Form 214 or electronic equivalent will be required for admission for the duration of EO 10466.

Author

Meredith DeMent counsels US and multinational companies across industry sectors on all aspects of US customs law. She focuses her practice on rapidly evolving trade policy, customs compliance, and duty mitigation strategies. She was named a rising star in international trade by Legal Media Group's Expert Guides.

Author

Eunkyung advices clients on various regulatory compliance and trade issues, concentrating on the US export controls such as the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR), economic and trade sanctions, US customs and import laws, the US Foreign Corrupt Practices Act (FCPA), and foreign anti-bribery laws.