U.S. Department of the Treasury

Yes.  E.O. 14068 prohibits the importation into the United States of fish, seafood, and preparations thereof; alcoholic beverages; and non-industrial diamonds of Russian Federation origin.  It does not prohibit U.S. persons from engaging in transactions to sell or re-direct shipments outside the United States that were previously destined for the United States.

In addition, the Office of Foreign of Assets Control (OFAC) has issued Russia-related General License (GL) 17A to authorize the import, for a limited time, of certain items pursuant to pre-existing written contracts or written agreements (see FAQ 1023).  GL 17A provides such authorization for importing alcoholic beverages or non-industrial diamonds of Russian Federation origin until March 25, 2022 and authorization for importing fish, seafood, and preparations thereof of Russian Federation origin until June 23, 2022.  OFAC may issue specific licenses on a case-by-case basis to authorize shipments occurring after the expiry of GL 17A or for other activity outside the scope of this GL. 

(Updated March 24, 2022)

Russia-related General License (GL) 17A  authorizes until March 25, 2022 transactions that are ordinarily incident and necessary to the importation into the United States of alcoholic beverages or non-industrial diamonds of Russian Federation origin pursuant to written contracts or written agreements entered into prior to March 11, 2022.  GL 17A also authorizes until June 23, 2022 transactions that are ordinarily incident and necessary to the importation into the United States of fish, seafood, and preparations thereof of Russian Federation origin pursuant to written contracts or written agreements entered into prior to March 11, 2022.  GL 17A does not authorize entry into new contracts.

Additionally, E.O. 14068 does not prohibit transactions such as the unwinding of contracts or other business-related activities by U.S. persons to comply with the import ban imposed under E.O. 14068.  Likewise, E.O. 14068 does not prohibit U.S. persons from engaging in transactions to sell or re-direct shipments outside the United States of prohibited imports previously destined for the United States.

Note that other prohibitions specified in E.O. 14068 are effective immediately. Additionally, with respect to the export prohibitions set forth in section 1(a)(ii) of E.O. 14068, please consult the U.S. Department of Commerce, Bureau of Industry and Security, for guidance.

(Updated March 24, 2022)