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President Biden Issues Executive Order Banning U.S. Imports of Russian Origin Oil, Gas, and Coal

President Biden Issues Executive Order Banning U.S. Imports of Russian Origin Oil, Gas, and Coal

On March 8, 2022, President Biden issued Executive Order 14066 which prohibits the following actions:

-The importation into the United States of any “crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products” of “Russian Federation origin”;

-New investment in the Russian energy sector by U.S. persons, wherever located; and

-Any approval, financing, facilitation, or guarantee by a U.S. person, wherever located, of any transaction conducted by a non-U.S. person that would be prohibited by Executive Order 14066 if performed by a U.S. person or within the United States.

The Executive Order further prohibits any transaction by anyone (whether a U.S. person or a non-U.S. person) that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of Executive Order 14066’s prohibitions, as well as conspiracies to violate the prohibitions.

In a Fact Sheet, the Biden Administration stated that the Executive Order is intended to “further deprive President Putin of the economic resources he uses to continue his needless war of choice”.  A  press release from the U.S. Department of the Treasury also stated that “[t]he United States continues to take severe action to hold the Russian Federation accountable for its brutal, unprovoked invasion of Ukraine.  Treasury has targeted the infrastructure supporting President Putin’s invasion of Ukraine”.

Executive Order 14066 is immediately effective.  However, the U.S. Treasury Department’s Office of the Foreign Assets Control (“OFAC”) has issued General License 16 authorizing all transactions that are “ordinarily incident and necessary to the importation into the United States” of certain products of “Russian Federation Origin”, if performed pursuant to written contracts or written agreements entered into prior to March 8, 2022.  The products of “Russian Federation Origin” authorized for import into the U.S. under General License 16 are:

-Crude oil;


-Petroleum fuels;

-Oils, and products of their distillation;

-Liquified natural gas; and

-Coal products.

General License 16 will remain effective until April 22, 2022, at which time all such transactions will be fully prohibited.  General License 16 does not  authorize any other actions that are prohibited under the existing Russian Harmful Foreign Activities Sanctions Regulations or transactions with persons who are otherwise subject to blocking sanctions unless such actions or transactions are separately authorized by OFAC.

OFAC also issued new Frequently Asked Questions (FAQ) guidance and updated existing FAQ guidance in order to clarify certain aspects of the Executive Order.  Among other things, these FAQs establish definitions for the terms “Russian Federation origin”, “new investment in the energy sector in the Russian Federation” and “energy sector”.  The FAQs also clarify that the Executive Order’s prohibitions do not extend to products that are not of Russian Federation origin “even if such products transit through or depart from the Russian Federation”.

Additionally, U.S. Customs and Border Protection (“CBP”) issued Cargo Systems Messaging Service Number 51260049 indicating that it will “be requiring filers of entries or admissions to Foreign Trade Zones for shipments of [the Russian Federation origin banned products] to provide purchase orders and/or executed contracts and/or any other documentation showing when the order and/or contract went into effect” through the expiration of General License 16 on April 22, 2022.  CBP also stated it will require the documentation prior to unlading and it “should include conveyance information, bill of lading number(s) and entry number(s) or FTZ admission information.”

Anyone reviewing Executive Order 14066 should also be aware of the significant sanctions and export controls that the U.S. government imposed on Russia prior to Executive Order 14066.


Grant Leach is an Omaha-based partner with the law firm Husch Blackwell LLP focusing on international trade, export controls, trade sanctions and anti-corruption compliance.

Cortney O’Toole Morgan is a Washington D.C.-based partner with the law firm Husch Blackwell LLP. She leads the firm’s International Trade & Supply Chain group.

Tony Busch is an attorney in Husch Blackwell LLP’s Washington, D.C. office and is a member of the firm’s International Trade & Supply Chain practice team.


The Solid Biofuel Market Grows Steadily Despite the Pandemic

IndexBox has just published a new report: ‘World – Solid Biofuels – Market Analysis, Forecast, Size, Trends and Insights’. Here is a summary of the report’s key findings.

The solid biofuel market continues to grow steadily. The pandemic generated financial and logistics problems for producers, but this failed to disrupt output, as a result of the consistent demand for long-term supply contracts. The production of wood pellets remains the fastest-developing segment on the solid biofuel market.

Key Trends and Insights

The solid biofuel sector remained stable during the pandemic, buoyed by existing long-term supply contracts. Despite facing disruptions in supply chains, constrained cash flows, and stagnating investment into new projects, solid fuel producers managed to sustain production levels and keep staff working.

The global pellet market grows rapidly with a CAGR of +11.9% a year over the past 8 years, emerging as the fastest-developing segment on the global solid biofuel market. Europe (44.8%) and North America (29.8%) remain major global pellet manufacturers (IndexBox estimates). China indicated the highest rate of production growth (with a CAGR of +31.1%) over the period from 2012 to 2020. Due to asynchronous quarantine measures in countries , the procurement of raw materials (sawdust) was disrupted, which emerged as a crucial issue for pellet manufacturers during the start of the pandemic in early 2020. Along with the ease of lockdowns in the second half of 2020, the supply chains were gradually readjusted.

The global charcoal market continued to expand at an average annual rate of +1.0% over the past 8 years and estimated at 56M tonnes (IndexBox estimates). The highest rate of consumption growth was observed in Africa (CAGR, +2.1%), the leading producer of wood charcoal worldwide (62%): in many low-income African countries, charcoal remains the main fuel available for cooking and daily living requirements.

According to IndexBox, the global solid biofuel market is forecast to reach 129.6M tonnes in the period to 2030 (this includes wood pellets and wood charcoal). The increasing demand for renewable fuels and the shifts towards a circular economy are set to remain the key market drivers. The use of plant residue (rice husks, straw, sugarcane, rapeseed, oil palm, and sugar beet etc.) as a raw material for the production of solid biofuel, is set to become increasingly prominent as a result of the robust crop yield.

Solid Biofuel Consumption by Country

The countries with the highest volumes of solid biofuel consumption in 2020 were the UK (9.4M tonnes), Brazil (6.6M tonnes) and China (5.2M tonnes), together comprising 21% of global consumption. Ethiopia, Nigeria, the U.S., the Netherlands, India, the Democratic Republic of the Congo, Germany, Italy, France and Viet Nam lagged somewhat behind, together accounting for a further 32%.

In value terms, the largest solid biofuel markets worldwide were China ($5.4B), Ethiopia ($2.9B) and Brazil ($2.7B), together accounting for 28% of the global market. The UK, India, Nigeria, the U.S., the Democratic Republic of the Congo, France, Germany, the Netherlands, Italy and Viet Nam lagged somewhat behind, together comprising a further 26%.

The countries with the highest levels of solid biofuel per capita consumption in 2020 were the Netherlands (170 kg per person), the UK (139 kg per person) and Ethiopia (42 kg per person).

Solid Biofuel Exports by Country

The U.S. was the key exporter of solid biofuels in the world, with the volume of exports amounting to 7.3M tonnes, which was near 27% of total exports in 2020. Canada (2.9M tonnes) occupied an 11% share (based on tonnes) of total exports, which put it in second place, followed by Latvia (7.8%), Russia (6.2%), Denmark (5.4%) and Viet Nam (4.6%). The following exporters – Estonia (1,070K tonnes), Germany (784K tonnes), Poland (681K tonnes), Austria (652K tonnes), Lithuania (616K tonnes), Portugal (616K tonnes) and Indonesia (570K tonnes) – together made up 19% of total exports.

Exports from the U.S. increased at an average annual rate of +18.9% from 2012 to 2020. At the same time, Denmark (+50.4%), Poland (+16.0%), Indonesia (+12.0%), Estonia (+11.7%), Latvia (+11.0%), Russia (+10.6%), Canada (+9.8%), Lithuania (+9.0%), Viet Nam (+8.0%) and Austria (+3.9%) displayed positive paces of growth. Moreover, Denmark emerged as the fastest-growing exporter exported in the world, with a CAGR of +50.4% from 2012-2020. Portugal experienced a relatively flat trend pattern. By contrast, Germany (-1.4%) illustrated a downward trend over the same period.

In value terms, the U.S. ($1B) remains the largest solid biofuel supplier worldwide, comprising 19% of global exports. The second position in the ranking was occupied by Canada ($408M), with a 7.6% share of global exports. It was followed by Latvia, with a 7.2% share.

Source: IndexBox AI Platform


Africa is Ready for Growth with Support from Trans-Ocean Transportation

RTM Lines is a trans-ocean transportation company headquartered in Norwalk, Connecticut, with over 39 years of experience in the global ocean carrier business. As a respected ocean transportation provider, we are continually equipping clients with valuable information and insight related to the ocean transportation industry.  Recently, RTM Lines has invested time and research to better understand the growth of African infrastructure and resources; and how those factors affect opportunities for growth and development in the breakbulk and project cargo markets. Research shows Africa resources and opportunities in key locations such as the Democratic Republic of Congo, Ethiopia, and Northern Mozambique. 

“Right now, the Democratic Republic of Congo (DRC) is sitting on the world’s largest cobalt resource, however the ongoing political turmoil, makes it very difficult to access the cobalt,” said Richard Tiebel, RTM’s Executive Vice President. He states, “Africa is showing more exponential growth than any other continent. Right now, markets like Ethiopia have shown 8% GDP growth, per annum. Analyzation shows there are a number of factors within urbanization, ICT (Telecommunications), and the Extractives Industry (Oil, Gas, and Mining) driving this growth.” 

With an array of potential possibilities for growth in Africa in the coming years, RTM Lines recommends directing attention to trades and the international markets in Africa, specifically in the shipping and trading processes. The growth and opportunities available in the African market, have great potential for clients that develop and understand the Africa market. 

“In the next 4-5 years, city populations in Africa will double, which means the infrastructure will need development. This development will motivate the community to build infrastructure that supply power, water, sanitation, housing developments, and support to serve the new population in the area. Most governments couldn’t support fixed-line infrastructures, but Africa is going through an information, communication, and technological revolution. The private sector is supporting this revolution and allowing Africans to pursue business opportunities. Companies like Microsoft have been investing in some African tech sectors, to develop talent and to take Africa forward,” said Tiebel.

As the International Maritime Organization (IMO) 2020 regulation will soon go into effect, Tiebel shared his perspective on how Africa’s natural resources can positively influence the trans-ocean transportation industry. 

Mr. Tiebel states, “the gas in Northern Mozambique is the world’s 12th largest natural gas resource. A lot of infrastructure will be needed in order to get this gas because the town itself is very small and scarcely has roads to support it, no port, no airport, or even power and electricity. The town of Palma will literally be built up in order to access this gas resource offshore.” He continues, “the cost of the IMO regulatory change on the shipping industry is unknown, and though we know the IMO’s decision will impact refiners, producers, bunker suppliers, and more, Africa offers a variety of natural resources to emerge as a major beneficiary of this regulation. This supply of natural resources has the potential to help the trans-ocean transportation industry control the anticipated spike in fuel costs in 2020.” 

RTM Lines is committed to providing customers the information necessary to ship ocean cargo with confidence. Understanding the changes and regulations in these expanding and shifting markets is key to providing smooth transit for infrastructure, mining, and oil & gas project cargo. RTM Lines is both knowledgeable and competent in global operations. Port to port, RTM Lines strives to improve the global trade market and the quality of the ocean transportation industry.