Morgan Lewis US and Russia Sanctions Update
CAATSA / Guidances / Lists
• CAATSA (Countering America's Adversaries Through Sanctions Act)
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Enacted in August 2017 (after passage through both Houses of Congress by
near-unanimous vote)
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Full text is here (PL 115-44) – the Russia-related part is Title II, sections
201-292
Eastern Ukraine / Crimea situation, alleged US (and European) election
meddling, and Syria were/are the three bases for it
Broadened toughened the pre-existing sanctions as contained in six
Executive Orders, the Ukraine Freedom Support Act of 2014 (the "UFSA")
and another 2014 law in support of Ukraine (now amended by CAATSA)
Also has framework authorization for some more primary sanctions (aimed
at US persons, or dealings having some other nexus to US) and secondary
sanctions (aimed at non-US persons - and not needing any US nexus)
Dramatically widened the gap between US and EU sanctions against Russia
(which has widened even further since then)
Morgan Lewis
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