was issued by President Joe Biden on December 22, 2023. The order amends EO 14024 and EO 14068 to expand the authority of the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) to impose secondary sanctions on foreign financial institutions (FFIs). These sanctions can be applied to FFIs that have conducted or facilitated any significant transaction or transactions for or on behalf of individuals or entities designated under EO 14024 for operating in specific sectors of the Russian economy, including technology, defense and related materiel, construction, aerospace, and manufacturing. The authority also extends to FFIs that have conducted or facilitated significant transactions or provided services involving Russia’s military-industrial base, including the sale, supply, or transfer to Russia of any item or class of items determined by the Secretary of the Treasury, in consultation with the Secretaries of State and Commerce.

The order introduces a new category of "critical items" subject to these sanctions, which include certain machine tools, manufacturing equipment for semiconductors and related electronics, electronic test equipment, propellants, chemical precursors for propellants and explosives, lubricants and lubricant additives, bearings, advanced optical systems, and navigation instruments. OFAC issued a determination on December 22, 2023, known as the "Russia Critical Items Determination," to identify these items. Notably, the secondary sanctions authority under EO 14114 applies even if the FFI did not knowingly engage in the prohibited conduct, establishing a standard of strict liability.

The penalties for non-compliance are severe and include full blocking sanctions (designation as a Specially Designated National) or restrictions on the opening or maintenance of correspondent accounts or payable-through accounts in the United States, effectively cutting off access to the U.S. dollar-based financial system. General License 84 allows for wind-down transactions for a 10-day period after the imposition of CAPTA sanctions, but no such license exists for full blocking sanctions. The U.S. government has emphasized its intent to use these new tools to target financial institutions that facilitate Russia’s military-industrial base, with Treasury Secretary Janet Yellen stating that OFAC "will not hesitate to use the new tools provided by this authority to take decisive, and surgical, action against financial institutions that facilitate the supply of Russia’s war machine".

In addition to expanding secondary sanctions, EO 14114 clarifies and expands the ban on importing certain Russian-origin goods into the United States, including fish and seafood, alcoholic beverages, non-industrial diamonds, and gold, now also applying to products imported from third countries that incorporate Russian content. OFAC also issued a Compliance Advisory on the same date to provide practical guidance to FFIs on identifying risks and implementing controls to mitigate exposure to these sanctions.

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