An executive order issued by President Biden in March 2022 banned imports of seafood of Russian origin. However, because such seafood has been processed into other products in other countries to bypass this restriction, Biden issued a new EO in December 2023 prohibiting imports of fish, seafood, and preparations thereof if they were mined, extracted, produced, or manufactured wholly or in part in Russia, harvested in waters under Russian jurisdiction, or harvested by Russia-flagged vessels, regardless of whether such products have been incorporated or substantially transformed into another product with a country of origin other than Russia.
The Office of Foreign Assets Control previously issued a general license allowing these newly-prohibited imports through Feb. 20. However, apparently due to shipping delays related to problems at the Panama Canal and in the Red Sea, OFAC has issued a new general license extending that deadline through May 30.
As a result, OFAC states that transactions ordinarily incident and necessary to the importation into the U.S. of subject goods that were loaded onto a vessel at the port of loading prior to 12:01 a.m. EST on Feb. 20, pursuant to written contracts or agreements entered into prior to Dec. 22, 2023, are authorized through 12:01 a.m. EDT on May 31.
U.S. Customs and Border Protection has added that beginning Feb. 20 all entry and certified from summary transactions, as well as goods admitted into a foreign-trade zone, that include the affected commodities will require purchase orders and/or executed contracts and/or any other documentation showing when the order and/or contract went into effect to be uploaded to the Automated Commercial Environment’s Document Image System.
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