Executive Orders 14024 and 13660 on the State of Emergency and US Anti-Russian Sanctions

Executive Order No. 14024 of April 15, 2021 (E.O. 14024) is one of the foundational documents upon which various anti-Russian sanctions were based. While Executive Order 13660 of March 6, 2014 (E.O. 1360), another foundational document, directly links sanctions against Russia to its unlawful actions regarding Ukraine, E.O. 14024 prescribes sanctions for “harmful foreign activities of the Russian government,” thereby outlining a much broader framework for possible anti-Russian sanctions.

Both Executive Orders declared a state of emergency due to Russia’s threat, which led to the imposition of sanctions. Moreover, these two Executive Orders became milestones in the US sanctions policy. Based on E.O. 13660, subsequent Executive Orders such as 13661, 13662, 13685, 13849, and 14065 were issued. Similarly, as a continuation and development of E.O. 14024, Executive Orders 14039, 14068, 14071, 14066, 14039, and 14114 were issued.

These Executive Orders, in addition to directly imposing sanctions, laid the groundwork for the imposition of new anti-Russian sanctions by the Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC).

US Anti-Russian Sanctions Based on E.O. 14024 Have Been Extended

The state of emergency declared in E.O. 13660, as well as the anti-Russian sanctions imposed based on it, were extended for another year on February 27, 2025, by a separate President Trump’s  Executive Order titled “Continuation of the National Emergency with Respect to Ukraine“. In turn, the state of emergency declared in E.O. 14024, as well as the US anti-Russian sanctions imposed based on it, were also extended for another year under a different Executive Order titled “Continuation of the National Emergency with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation“.

The time gap between the extensions of these two state of emergency provisions and the corresponding sanctions is due to the timing of the initial documents. E.O. 13660 was adopted on March 6, 2014, and has since been extended every year. Therefore, it had to be extended no later than March 6 to ensure the continuation of the state of emergency and anti-Russian sanctions. As a result, the new Executive Order for extension was issued on February 27, 2025. E.O. 14024 was adopted on April 15, 2021, and has also been extended annually. Therefore, it needed to be extended no later than April 15, 2025, which was done on April 10 of this year.

The Significance of Extending the State of Emergency and Sanctions

If during the presidencies of Obama and Biden, the extension of the state of emergency and sanctions against Russia could be considered almost a technical matter, under President Trump, as we can see, everything changed. The question of what the new US president might do in this regard remains a mystery for many. This is due to the rather eccentric behavior of the head of the American administration on the international stage in general and in relation to Russia in particular. This, in turn, has generated a host of various hypotheses of the most unexpected nature, ranging from assumptions of even harsher behavior towards Russia to conspiracy theories about Trump and Putin conspiring against the Western world.

The prospect of a tougher stance toward Russia under the new U.S. administration was widely discussed even before Trump took office, both by his supporters and by candidates for key positions in his cabinet. However, no such shift in policy has materialized so far. Instead, other theories have gained traction, particularly among members of the Democratic Party, who have raised concerns about Trump’s seemingly soft approach to Russia and Putin, especially in light of the ongoing bombardment of Ukraine. Trump and his cabinet members have defended this position, framing it as a strategic decision to “keep the door open” for potential negotiations with Putin.

In this context, extending the state of emergency under Executive Orders 13660 and 14024 is not merely a technical matter. These extensions underscore the continuity of U.S. sanctions policy toward Russia, signaling that sanctions against Russia remain entirely in place. Moreover, as has recently been revealed, Trump has threatened Russia with even tougher sanctions if Putin does not agree to a ceasefire in the near future.

Conclusion

Thus, not only have U.S. sanctions against Russia been extended for another year in full, but the legal framework for imposing new sanctions remains intact, should the Trump administration deem it necessary. This is quite likely if, in the coming weeks or months, his peace efforts do not succeed and the war in Ukraine is not halted.

In this context, delaying addressing issues related to sanctions does not make sense. As US administration officials have repeatedly emphasized, even easing some anti-Russian sanctions, such as those affecting air travel between the US and Russia or financial transactions, is contingent on achieving a ceasefire and making tangible progress toward a peace agreement. However, recent developments, including several negotiations between the US and Russia, indicate that no major breakthroughs should be expected anytime soon, neither in resolving Ukraine’s conflict nor lifting sanctions.

If you need an OFAC license or want to be removed from the OFAC SDN list, please contact us. We are ready to quickly assist with any OFAC and US anti-Russian sanctions issues.