Morgan Lewis US and Russia Sanctions Update
Export Pipeline Sanctions
See latest legal/political/practical Nord Stream 2-related developments at slides
7-8 above - including
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One of Russia's two main pipelaying vessels, the Fortuna, has been SDN'd under
PEESA and CAATSA
PEESCA / NDAA 2021 (see summary at slide 8) - further expansion of existing NDAA
2020 Nord Stream 2 (and TurkStream 2) sanctions ... see just below
Not yet clear how will all play out
NDAA 2020 enacted in Dec. 2019 (section 7503, pp. 1103-1107 as relates to
Russian export pipelines - PEESA) essential contents
Supplemented the pre-existing (and since further stiffened) CAATSA sec. 232 (see slides 52
and 62) but aimed specifically at pipe-laying vessels and foreign persons participating in
this
President shall (upon the mandated initial 60-day and thereafter 90-day report dates)
exercise powers to block all property / interests in the US etc. of any company that is in
violation of the requirements as of 20 Dec. 2019 enactment date - subject to wind-down,
exceptions and waiver provisions (see next slide)
And exclude corporate officers and controlling shareholders of the above from entry into the
US (or other involved foreign persons), and possible related blocking of property/interests
Morgan Lewis
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