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1020. Does Executive Order (E.O.) 14066 prohibit dealing in Kazakh-origin crude oil of the Caspian Pipeline Consortium (“CPC”)?


No.  The importation prohibition of E.O. 14066 applies to the import of certain products of Russian Federation origin to the United States and excludes imports that are not of Russian Federation origin, even if such items transit through or depart from the Russian Federation.  The CPC transports crude oil through the CPC pipeline that is predominantly of Kazakh origin and that is marketed and loaded with a certificate of origin verifying that the crude is of Kazakh origin.  Any crude oil that is primarily of Russian Federation origin is marketed and loaded separately and certified as Russian origin.  For purposes of assessing whether crude oil marketed by the CPC is of Russian origin, U.S. persons may reasonably rely upon a certificate of origin, but should exercise caution if they have a reason to believe such certificate has been falsified.

Date Updated: 03/18/2022

Date Released
March 8, 2022