On February 21, 2022, President Biden signed an Executive Order (E.O.) responding to President Putin’s recognition of the Donetsk and Luhansk People’s Republics (DNR and LNR), located in Ukraine, as “independent” states. According to the E.O. fact sheet [3] released by the White House, the E.O. prohibits new investment, trade, and financing by U.S. persons to form in those regions and “the importation into the United States, directly or indirectly, of any goods, services, or technology from the so-called DNR or LNR regions of Ukraine,” among other things. Along with sanctions, the E.O. also issued “six General Licenses to ensure that humanitarian and other related activity can continue in [those] regions.”