# Class Deviation 2024-O0006
# Class Deviation 2024-O0006 – Prohibition Regarding Russian Fossil Fuel and Fossil Fuel Business Operations

Status: Archived
Date Issued: 2024-02-06
Signed By: John M. Tenaglia, Principal Director, Defense Pricing and Contracting
Scope: All DoD contracting officers
Authority: Section 804 of the National Defense Authorization Act for Fiscal Year 2024 (Pub. L. 118-31)

## Summary

This deviation implements section 804 of the FY2024 NDAA, which prohibits DoD from contracting with entities that are at least 50 percent owned by the Russian government or by fossil fuel companies operating in Russia. Contracting officers must include a new representation provision and a new prohibition clause in solicitations and contracts above the simplified acquisition threshold, including commercial acquisitions. Limited exceptions apply for humanitarian, national security, diplomatic and licensed operations, and contracting officers must notify Defense Pricing and Contracting when any exception is used.

## Required Contracting Officer Actions

1. Include provision 252.225-7966 in all solicitations that also include clause 252.225-7967.
2. Include clause 252.225-7967 in solicitations and contracts, including those using FAR part 12 procedures for commercial products and services, valued above the simplified acquisition threshold, unless a specific exception applies.
3. When awarding a contract under an exception, notify Defense Pricing and Contracting, Contract Policy at osd.pentagon.ousd-a-s.mbx.dpc-cp@mail.mil and include a copy of the joint determination by the Secretary of Defense and Secretary of State.
4. Include a copy of the joint determination in the contract file whenever a contract is awarded on the basis of an exception.

## Affected Provisions and Clauses

### 252.225-7966, Prohibition Regarding Russian Fossil Fuel Business Operations—Representation (Provision)
- Change type: NEW
- Action: New provision created by this deviation; use in solicitations that include clause 252.225-7967.

### 252.225-7967, Prohibition Regarding Russian Fossil Fuel Business Operations (Clause)
- Change type: NEW
- Action: New clause created by this deviation; use in solicitations and contracts above the simplified acquisition threshold including commercial acquisitions.

## Notes

Exceptions to the prohibition: The prohibition does not apply to contracts jointly determined by the Secretary of Defense and Secretary of State to be necessary for humanitarian assistance to the people of Russia, disaster relief or urgent lifesaving measures, vital to U.S. national security interests, or covering a fossil fuel business operation in a country other than Russia entered into before the effective date. Contracts related to operation of U.S. consular offices and diplomatic posts in Russia, or licensed or authorized by the Office of Foreign Assets Control, are also excepted.

Expiration: The deviation remains in effect until December 31, 2029, or until incorporated into the DFARS or otherwise rescinded.

Point of contact: Questions may be directed to Mr. Jeffrey Grover, DPC/CP at jeffrey.c.grover.civ@mail.mil.

## Suggested Questions

You can ask your AI assistant:
- What actions do I need to take for this deviation?
- Does this deviation affect commercial acquisitions under Part 12?
- Which clauses need to be removed from my existing contracts?
- How does this deviation change 252.225-7966 specifically?
- Are there any SAM registration implications?

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Source: https://part52.dev
Generated: 2026-03-20
Memorandum: https://www.acq.osd.mil/dpap/policy/policyvault/USA000279-24-DPC.pdf