Trump Extended Sanctions for One More Year

On February 27, 2025, Trump extended sanctions against Russia, introduced in 2014, 2018, and 2022 in connection with the violation of Ukraine’s territorial integrity. February 24 marks three years since Russia’s full-scale invasion of Ukraine. In this context, the EU released a new sanctions package, one of the largest and most significant in the history of the European Union’s sanctions policy. The import of aluminum was banned, another 13 Russian banks were disconnected from SWIFT, 74 vessels from third countries, which are part of the so-called “shadow fleet,” were added to the sanctions list, 48 individuals and 35 legal entities, etc.

The United States did not respond to this anniversary, which evidently caused confusion and criticism from their European partners. Furthermore, Ukrainian President Zelensky’s visit to Washington was scheduled for February 28 to sign an agreement with Trump on rare earth metals. Therefore, the timing of the extension of U.S. sanctions against Russia was not accidental: with some delay, but still immediately after the third anniversary of the start of the military actions and just one day before the Ukrainian President’s visit.

Notice of the President of the United States on the Extension of Sanctions

The extension of U.S. sanctions against Russia has been issued in the form of a Presidential Notice and published in the Federal Register – the official government publication of the United States. The title of this notice is significant – “Continuation of the National Emergency with Respect to Ukraine.” The reason for this is that the basis for all sanctions imposed, specifically against Russia, is the declaration of a national emergency by the President of the United States. Such a declaration is made based on the International Emergency Economic Powers Act.

Therefore, the notice about the extension of the national emergency status does not just signify the extension of sanctions but actually acknowledges that the grounds for imposing the sanctions continue to exist. This could also indicate that new sanctions against Russia may soon be forthcoming. Although, by law, a national emergency is not restricted by strict time limits, the President of the United States must extend it every year through the appropriate legal act, which also explains the reasons for the extension. In this case, it is stated that the situation, which led to all previous U.S. Presidential Orders imposing sanctions on Russia since 2014, remains unchanged.

Why Is Executive Order No. 14024 Not Mentioned in the U.S. Presidential Notice?

The U.S. Presidential Notice, which is, in fact, an Executive Order, contains numerous references to previous Executive Orders imposing sanctions on Russia in connection with Ukraine, as well as the relevant legislation under which these orders were issued. For example, the Notice mentions Executive Orders No. 13660, 13661, 13662, 13685, 13849, and 14065. As a reminder, President Obama’s Executive Order No. 13660 of March 6, 2014, was the starting point for the national emergency, which has since formed the basis for all subsequent sanctions against Russia. Therefore, this emergency had to be renewed annually until March 6 each year. By renewing it for another year, Trump confirmed that there had been no fundamental changes in U.S. sanctions policy and that new sanctions could be expected soon.

However, it is noteworthy that Executive Order No. 14024, issued by President Joe Biden on April 15, 2021, is not mentioned in this Notification. This order is frequently referenced by U.S. authorities, particularly OFAC, when imposing sanctions on individuals and companies in connection with Russia’s actions in Ukraine. The reason for this omission is unlikely to be found in any personal animosity between Trump and Biden, which Trump has openly demonstrated over a long time.

The fact is that the U.S. sanctions policy toward Russia consists of two distinct blocks of sanctions. The first includes sanctions imposed on the Russian Federation for violating Ukraine’s territorial integrity, beginning in 2014. The second block consists of sanctions imposed on Russia due to its so-called “harmful foreign activities” —a term encompassing cyberattacks, interference in U.S. elections, and various other actions that the U.S. authorities view as aggressive behavior by Russia. The basis of this second sanctions package is U.S. Presidential Executive Order No. 14024, titled “Blocking Property With Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation”.

The extension of the state of emergency relates to the executive orders imposing sanctions against Russia in connection with Ukraine, beginning in 2014. As for the sanctions related to Russia’s “harmful activities,” which are centered around Executive Order No. 14024, a separate U.S. Presidential Executive Order will likely be issued to extend the state of emergency associated with this particular set of sanctions.

Conclusion

As we can see, the landscape of sanctions against Russia has not changed for now. The EU has adopted a new 16th sanctions package, while Trump extended sanctions against Russia for one more year. Since no agreement on a ceasefire has yet been reached, it is unlikely that we can expect a swift resolution of the conflict and the subsequent lifting of sanctions. Most likely, this will be a long and challenging process, the outcome of which is hard to predict.

Therefore, it is crucial to address issues related to sanctions immediately rather than waiting for a “political decision” that, if it occurs, could take a considerable amount of time. For instance, due to ongoing territorial disputes, Russia and Japan have yet to sign a peace treaty following World War II.

If you have an issue related to U.S. sanctions, contact us. We will quickly assess your situation and suggest an appropriate solution.