1024. I have a shipment of a certain product(s) listed in Executive Order (E.O.) 14068 en route to the United States that were contracted prior to March 11, 2022.  Can I find a new buyer for this shipment, re-direct the shipment to a country other than the United States, or import the product(s) and comply with the import ban?

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)