On February 20, 2024, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License (GL) 83A, “Authorizing Certain Transactions Related to Imports of Certain Categories of Fish, Seafood, and Preparations Thereof Prohibited by Executive Order 14068.”

On March 11, 2022, President Biden issued EO 14068 to prohibit, among other transactions, the importation into the United States of any Russian-origin “fish, seafood, and preparations thereof.” This initial iteration of EO 14068 did not prohibit the importation of Russian-origin seafood that was incorporated or substantially transformed into another product (e.g., processed) outside of Russia. See FAQ 1154 & FAQ 1156.

On December 22, 2023, President Biden amended EO 14068 with EO 14114, extending this prohibition to capture “the importation and entry into the United States, including importation for admission into a foreign trade zone located in the United States” of identified categories of Russian-origin seafood, even if such seafood was incorporated or substantially transformed into another product in a third country. Also, OFAC simultaneously (1) issued a “Seafood Determination” that identified salmon, cod, pollock, and crab as the categories of Russian-origin seafood that are subject to this expanded prohibition (see FAQ 1155); and (2) issued General License 83, which authorized through 12:01 AM EST on February 21, 2024, all transactions that are ordinarily incident and necessary to the importation into the United States of these otherwise prohibited “seafood derivative products,” pursuant to written contracts or written agreements entered into prior to the December 22, 2023 Seafood Determination. 

GL 83A extends the deadline in GL 83 to 12:01 AM EST on May 31, 2024, provided that the relevant Russian-origin “seafood derivative products” are “loaded onto a vessel at the port of loading” prior to 12:01 AM EST on February 20, 2024, pursuant to written contracts or written agreements entered into prior to the December 22, 2023 Seafood Determination. In other words, GL 83A does not authorize transactions – such as shipments – involving seafood derivative products that were loaded onto a vessel at the port of loading at or after 12:01 AM EST on February 20, 2024.