Morgan Lewis US and Russia Sanctions Update
CBW Act Sanctions (cont'd)
The President (in consultation with Congress) will be required to impose at
least three of the following six possible further sanctions:
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Opposing loans/assistance from multilateral development banks (IFIs – e.g., World
Bank, IMF)
Ban on US banks making almost any loan or providing any credit to the RF Gov't
Additional restrictions on exports of goods or technologies to Russia
Restrictions on the imports into the US of articles (which may include petroleum or
any petroleum products) produced in Russia
Downgrading or suspension of diplomatic relations
Ban on air carriers owned or controlled (directly or indirectly) by the RF Gov't from
flying to or from the US
But note that in fact three of these enhanced-penalty menu items were already
imposed, in August 2019 (see next slide), as second round of Skripal-related
sanctions for Russia's failure to meet the above-noted conditions
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By Trump Administration Executive Order ("EO") 13883, and follow-on clarifying State
and OFAC releases - and again with various narrowing interpretations, exceptions and
waivers
Morgan Lewis
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