Meta description: Comprehensive 2026 guide to OFAC’s Executive Order 14024 framework: the anatomy of Russia sanctions, the oil price cap status, the secondary sanctions on foreign banks, the REPO Act, and the day to day realities facing compliance teams.
Five years after it was signed, Executive Order 14024 has become the most operationally complex sanctions program administered by OFAC. It is also the most erratic. During January 2025 to April 2026, the framework included a final wave of Biden era designations, the Trump administration’s initial Russia related actions, a temporary opening of the oil market due to the Iran conflict, partial divergence with G7 partners on the price cap, and early implementation of the REPO Act to benefit Ukraine. The compliance reality on the desk of a sanctions officer in Istanbul, Dubai or Almaty in 2026 has only a passing resemblance to the one they were navigating in 2022.
This guide breaks down the EO 14024 framework as it really is in 2026. The legal architecture, the sectoral perimeter, the general licenses, the secondary sanctions exposure for non U.S. banks, the regional comprehensive regimes and the operational mechanics that compliance programmes have to run on it every day The following sections will cover these in depth:
- The Russia Sanctions Architecture: Three Intersecting Programs
- EO 14024 Framework: Authority and Scope
- Sectors Under Restrictions
- Oil Price Cap Regime
- Secondary Sanctions on Foreign Financial Institutions
- The 50% Rule in the Russian Context
- General Licenses: What Is Permitted Today?
- Crimea, Donetsk, Luhansk, Zaporizhzhia, Kherson: Complete Regional Sanctions
- The REPO Act and Russian Sovereign Assets
- Compliance Operational Reality for 2026
The Russia Sanctions Architecture: Three Intersecting Programs
OFAC does not have a single "Russia program." It has three, and they are intentionally overlapping.
The first is the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR), codified at 31 CFR Part 587, which implements EO 14024 and the series of executive orders amending it. RuHSR is the architecture post 2021 and the core of current enforcement.
The second is the Ukraine/Russia Related Sanctions under EOs 13660, 13661 and 13662, the 2014 framework originally built around the annexation of Crimea. Those orders are still in effect. And they matter. In January 2025, OFAC re-designated over 100 persons under E.O. 13662, determined to operate in the Russian economy in the financial services, energy, and defense and related materiel sectors, and who were already designated under E.O. 14024. Why re designate? Countering America's Adversaries Through Sanctions Act (CAATSA) carries heightened secondary sanctions risk for designations under EO 13662, and requires Congressional approval to remove them. The re-designations were a conscious ratchet; harder to undo, harder for non U.S. counterparties to dismiss.
Third is Magnitsky, the Global Magnitsky framework under EO 13818 (and the original Sergei Magnitsky Rule of Law Accountability Act). Magnitsky designations are meant for those involved in human rights abuses and significant corruption. Many Russian oligarchs and security officials are tagged under Magnitsky, along with EO 14024.
The practical takeaway is that an Specially Designated Nationals (SDN) entry on the Russia part of the list often has multiple program tags at the same time: “RUSSIA-EO14024”, “UKRAINE-EO13662”, “GLOMAG”. Each tag has its own legal authority, its own removal pathway, its own secondary sanctions footprint. A compliance program that screens against only one doesn’t see the bigger picture.
EO 14024 Framework: Authority and Scope
EO 14024 was issued on April 15, 2021, pursuant to the International Emergency Economic Powers Act (IEEPA) and the National Emergencies Act. It declared a national emergency with respect to certain harmful foreign activities of the Government of the Russian Federation, including election interference, malicious cyber activity, transnational corruption and efforts to undermine democratic institutions in the United States and abroad.
The architecture is a sectoral one. EO 14024, Section 1(a)(i) authorizes the U.S. Treasury, in consultation with the State Department, to designate any person determined to operate or have operated in a sector of the Russian Federation economy “as may be determined” by Treasury. Each determination opens up a new sector for designation authority and each has, in turn, become a tool for escalation.
To date, determinations have been made for financial services (February 22, 2022), aerospace, electronics and marine (March 31, 2022), metals and mining (February 24, 2023) and most notably, energy (January 10, 2025), a determination Treasury made in the later days of the Biden administration. Each finding is prospective: It does not in and of itself designate anyone, but expands the universe of persons that OFAC may designate going forward.
The framework has been progressively expanded in a series of subsequent executive orders. EO 14039 (August 2021) targeted the Nord Stream 2 pipeline. EOs 14066 and 14068 (March 2022) prohibited Russian origin oil, coal, gas and certain other imports, and certain new investment. EO 14071 (April 2022) had prohibited new investment in Russia and the provision of accounting, management consulting and IT services. And EO 14114 (December 22, 2023) transformed the entire program by providing OFAC explicit authority to impose secondary sanctions on foreign financial institutions dealing with Russia’s military industrial base.
Sectors Under Restrictions
The sector perimeter is large in 2026. There are six categories that matter most.
Financial services: The first shot in February and March 2022 imposed full blocking sanctions on Sberbank, VTB, Bank Otkritie, Sovcombank, Novikombank, Promsvyazbank, VEB and others. In April 2022, Alfa-Bank followed suit. The EU and UK, in parallel and not under OFAC authority, applied SWIFT disconnections to selected Russian banks. The U.S. CAPTA Directive (Directive 2 under EO 14024) prohibits correspondent and payable through accounts for designated Russian banks at U.S. financial institutions. Combined effect is by mid 2022, all major Russian banks were cut off from the U.S. financial system and a major part of the European one.
Energy: Sectoralized under EO 13662 from 2014, then put under blanket new investment prohibitions in 2022, then re-energized as a designation target by the January 10, 2025 EO 14024 determination. The October 22, 2025 designation of Rosneft and Lukoil, the Trump administration’s first new Russia related sanctions, added the country’s two largest oil producers and more than two dozen of their named subsidiaries to the SDN List. The October 22, 2025 designations, together with the January 2025 sanctions imposed by President Biden on Gazprom Neft and Surgutneftegas, place the four largest oil companies in Russia under the U.S. blocking sanctions.
Defense: The EO 14024 and EO 13662 designations comprehensively target the Russian defense industrial base, including state owned defense conglomerates, design bureaus, and supply chains. March 2022 saw the aerospace determination include United Aircraft Corporation, helicopter makers, and avionics suppliers.
Tech: The OFAC works closely with the Bureau of Industry and Security (BIS) in the Department of Commerce which administers export controls under the Export Administration Regulations (EAR). The Common High Priority Items List, which is co-issued with the G7 and EU partners, identifies battlefield relevant items, and whose diversion to Russia leads to greater scrutiny of compliance.
Metals & Mining. This area was opened by the February 24, 2023 determination. Designations have included producers of aluminum, nickel, and steel, with carveouts (via GL 6D and others) for civilian nuclear, medical isotopes, and humanitarian uses.
Diamonds. The G7 ban on the importation of Russian origin diamonds, phased in through 2024, runs parallel to OFAC restrictions under EO 14068 as amended by EO 14114.
The Oil Price Cap Regime
The price cap was supposed to be slick. Allow Russian oil to flow to world markets so prices don’t go through the roof but put a cap on how much Russia can earn from each barrel.
The cap, introduced in December 2022 by the G7, the EU and Australia, initially set the $60 per barrel ceiling on Russian crude and for separate caps on premium and discount petroleum products. The mechanism used by service provider attestation: Western maritime services (insurance, flagging, financing, brokering, shipping) were permitted only for cargoes sold at or below the cap and providers had to obtain attestations from the relevant counterparties certifying compliance.
It is not yet clear what will happen with the cap in 2026. In July 2025, the US did not support lowering the Oil Price Cap to limit the Russian energy revenues used to fund the conflict in Ukraine. Then the EU brought its cap down to $47. And then to $44. The U.S. did| not follow.
More dramatically, the March 2026 issuance of general license 134 (and its successors 134A and 134B), temporarily superseded the cap regime altogether for covered cargoes. On April 17, 2026, OFAC issued Russia related General License 134B, which extends the authorization of transactions ordinarily incident and necessary to the sale, delivery or offloading of Russian origin crude oil or petroleum products loaded onto vessels on or before April 17, 2026 EDT. GL 134B authorization is valid until May 16, 2026. The rationale behind was stabilization of the oil market after the disruption of the Strait of Hormuz.
For compliance teams, the practical implication is that the cap regime will be in operation in 2026 with significant temporal carve outs, while nominally still in place on paper. Service provider attestation, vessel tracking and cargo loading date verification are still in play. But there is also the risk of a general license extension lapsing without warning, thereby reverting covered cargoes to full prohibition.
Secondary Sanctions on Overseas Financial Institutions
The most important development since 2022 is EO 14114, signed December 22, 2023.
EO 14114 amended EO 14024 to explicitly authorize OFAC to sanction foreign financial institutions, not just US ones, that carry out or facilitate significant transactions with Russia’s military industrial base. If OFAC makes a determination, OFAC may prohibit the opening or prohibit or strictly condition the maintenance of correspondent or payable through accounts in the United States, or take full blocking measures against the institution.
The regime was operationally burdensome due to guidance issued June 12, 2024 expanding the definition of “Russia’s military industrial base.” On June 12, 2024, OFAC amended the definition of “Russia’s military industrial base” to include all persons blocked under E.O. 14024. The term, once limited to actors in technology, defense, aerospace, construction and manufacturing, was broadened to include anyone listed under EO 14024, financial sector persons included. Foreign financial institutions that conduct or facilitate significant transactions or provide services involving persons blocked under E.O. 14024 face OFAC sanctions unless facilitating allowable transactions related to food, agriculture, medicine, energy, and telecommunications.
The threat is now real. In the January 2025 actions, OFAC designated a bank in the Kyrgyz Republic under E.O. 14024 for conducting or facilitating material transactions for or on behalf of a designated Russian bank, pursuant to its secondary sanctions designation authority under the amended E.O.
The operational exposure has reshaped the business of banks in Turkey, the UAE, the Central Asian republics and other corridors with sizeable Russia related trade volume. Access to the U.S. financial system by correspondent banks relies on the ability to demonstrate upon demand that any transaction with a Russia element has been screened against the entire EO 14024 universe, and not just the older sectoral designations. Many banks now won’t take the run risk and refuse Russia related business altogether. Others have built specific screening, due diligence, and transaction monitoring stacks for the post EO 14114 environment.
The 50% Rule in the Russian Context
OFAC’s 50 Percent Rule is not unique to Russia. But it gets its heaviest workout in Russia.
The rule is simple in principle, and has been embodied in OFAC guidance since 2014 and updated in detail through 2022: Any entity that is owned 50% or more, directly or indirectly, individually or in the aggregate, by one or more blocked persons is itself blocked, automatically, even if it is not on the Specially Designated Nationals (SDN) List. The corollary, less appreciated, is that the rule works in the aggregate. Two SDNs each owning 30% in a subsidiary blocks the subsidiary despite neither individually crossing the threshold.
This is disproportionately important in the Russian context. Russian oligarch ownership structures are multi layered, opaque, and often directed through jurisdictions where corporate registry data is sparse. This could be an example of a Maltese holding company which is 51% owned by a British Virgin Islands entity whose ultimate beneficial owner is an SDN which owns a trading company in Cyprus. The chain must be walked, and walked accurately, before establishing the legal status of the trading company. This came to a head with the October 2025 Rosneft and Lukoil designations: Under OFAC’s 50% Rule, any further entities owned 50% or more, directly or indirectly, individually or in the aggregate, by Rosneft, Lukoil and/or any of their designated subsidiaries, are also blocked persons.
OFAC’s guidance from December 2022 significantly tightened the analysis posture with Russia very much in mind. The guidance reminded institutions that aggregate ownership analysis is required, that indirect ownership must be traced through chains, and that beneficial ownership opacity is not a defense. In practice, compliance programs use specialized data sets, corporate registries, leaked document repositories, OSINT, to build ownership graphs, and compare them to daily SDN updates.
General Licenses: What is Permitted Now
OFAC issues general licenses (GLs) to authorize classes of transactions otherwise prohibited under the RuHSR . The only way to know what compliance teams may actually do, in the true sense of the word, is to read the current GL inventory.
Day to day operations are based on a number of GLs:
GL 6D allows transactions for agricultural commodities, medicine, medical devices and some industrial isotopes for nuclear medicine, the core humanitarian carveout. GL 8 (as amended from time to time) authorizes certain energy related transactions with designated Russian financial institutions with periodically reset wind down dates; OFAC amended GL 8L on January 10, 2025 to authorize wind down of energy related transactions involving certain Russian financial institutions designated pursuant to E.O. Subsequent versions have been forthcoming. GL 13Q, April 8, 2026 Authorizes certain administrative transactions otherwise prohibited by Directive 4 under EO 14024 (the Central Bank / NWF / Ministry of Finance directive). GL 14 allows for certain, narrowly defined clearing and settlement transactions with Directive 4 entities. GL 25G (October 2024) permits telecommunications and some internet based communications.
A second cluster relates to the designations of Rosneft/Lukoil in October 2025. GL 124B allows activities related to the Caspian Pipeline Consortium, Tengizchevroil and Karachaganak projects when Rosneft, Lukoil or their majority owned subsidiaries are involved. GL 126, 127 and 128 permitted time limited wind down activities. Specifically, GL 128A allows for the maintenance and sale of Lukoil retail service stations located outside of Russia.
A third cluster, the GL 134 / 134A / 134B series, covers the temporary reopening of the oil market from March 2026.
GL expiration tracking is now a separate discipline of compliance. A silent expiration of a GL can turn lawful activity into a sanctions violation overnight, and OFAC offers no reminder.
Crimea, Donetsk, Luhansk, Zaporizhzhia, Kherson: Complete Regional Sanctions
Besides the sectoral regime, OFAC also administers near comprehensive embargoes on five Russian occupied regions of Ukraine.
In December 2014, Executive Order 13685 imposed comprehensive sanctions on Crimea, barring new investment, the import or export of goods, services or technology to or from Crimea, and the facilitation of such transactions. EO 14065 (February 2022) extended the same architecture to the Donetsk and Luhansk regions. Since then, further rulings under these orders, and similar measures, have offered near universal coverage in the Zaporizhzhia and Kherson oblasts following Russia’s annexation in September 2022.
Practically, this means that almost any transaction with a person located in, or organized under the laws of, these regions is prohibited unless a specific license is obtained from OFAC. Existing general licenses (humanitarian aid, journalistic activity, agricultural commodities, telecommunications, official government business) are few and narrowly drawn.
Regional regimes push aggressively into the rest of the framework. The GL 134B authorization for Russian-origin oil specifically prohibits transactions involving persons located in or organized under the laws of Crimea, Donetsk, or Luhansk. GL coverage is immediately broken if a vessel loads at a Russian-administered port in these areas or if a counterparty is registered there.
The REPO Act and Russian Sovereign Assets
After much deliberation, Congress passed the Rebuilding Economic Prosperity and Opportunity (REPO) for Ukrainians Act, and the President signed it in April 2024. The legislation authorized the president to seize Russian sovereign assets in the United States, and transfer such assets to a Ukraine Support Fund, to be administered by the State Department.
U.S. share of frozen Russian sovereign assets is modest. It is estimated that between $4 billion and $5 billion dollars of the $300 billion dollars of Russian sovereign assets frozen worldwide are subject to US jurisdiction. The bulk, including about €210 billion at Euroclear in Belgium, is in the EU.
The most important practical output of the REPO Act to date is the G7 led Extraordinary Revenue Acceleration (ERA) Loan. In October, the United States and G7 countries announced a $50 billion collective loan to Ukraine, to be repaid from funds generated by a portion of Russia’s frozen sovereign assets held in Belgium.
In October 2025 a follow on bill, the REPO Implementation Act of 2025, was introduced. The bill would put about $5 billion of frozen Russian sovereign assets under U.S. jurisdiction into an interest bearing account and call on the President to use at least $250 million from the account to provide aid to Ukraine every 90 days. The bill has not been enacted as of 2026.
The REPO side of compliance means looking ahead. Institutions that hold any Russian sovereign assets, Central Bank, sovereign wealth, RDIF, should comply with REPO authorities, executive orders, and any specific licenses issued under the act, because the actual transfers will be processed through OFAC mechanisms.
Compliance Operational Reality for 2026
What does running an EO 14024 compliance program look like in 2026? The year is set by five operational realities.
Daily churn of SDN list. OFAC publishes additions, deletions and corrections to the SDN List on an unscheduled basis, and 2026 has seen movement both ways: New designations that reflect Trump era priorities, and a measurable number of delistings of UAE and Turkey based entities previously designated for Russia evasion. If you do a static screening run on Monday, it’s a stale by Thursday. Running automated rescreening against daily list deltas is no longer a “nice to have”.
Multi program screening. A single counterparty can have RuHSR tags, Ukraine /Russia related tags and Magnitsky tags simultaneously. Program tags as a screening filter (e.g. “Russia only”) miss the cross pollination, and CAATSA secondary sanctions risk attached to EO 13662 designations.
50% Rule aggregate analysis. Beneficial ownership graphs should be created and maintained on an ongoing basis with aggregation logic that factors in multiple SDN owners exceeding the 50% threshold in the aggregate. Static ultimate beneficial owner (UBO) onboarding documents are not enough.
Secondary-sanctions risk assessment for non-U.S. firms. Banks, fintechs, payment processors and trading firms outside the United States are now directly exposed to OFAC risk on Russia activity. The June 2024 expansion of “military industrial base” to all EO 14024 designations means that the safer looking transactions of 2023, i.e., the transactions that touched financial sector SDNs but not “Moscow Industrial Bank” SDNs, are now firmly in the secondary sanctions perimeter.
General License expiration tracking. GLs expire, are amended, are superseded. Compliance teams need a GL inventory that includes effective dates, expiration dates, supersedes by relationships, and an alerting layer to flag expirations before they occur.
This is the world that EO 14024 has created. The framework is dense, the perimeter shifts week to week, and the stakes of getting it wrong are correspondent banking access, license revocation and full secondary blocking. The institutions that do well in 2026 will be those that treat EO 14024 not as a list to screen, but as a living system to operate inside.
