US Sectoral Sanctions

Basic Framework - US/EU (cont'd) CAATSA enacted August 2017 (and State / Treasury Guidelines of Oct. 2017) - and see: - Full summary discussion at slides 47-61 The Jan. 2018 CAATSA-based Reports/Lists for Congress (see slides 56-57) And note the Sept. 2018 CAATSA-implementing EO (see slide 58), and proposed DASKA Act would further broaden CAATSA (see slides 5 and 70) ... and CAATSA sec. 232 scope recently expanded (see slide 8) Various cyber- and defense-related CAATSA secondary-sanctions designations of Russian / other foreign entities to date (see slides 41-43 and 51-52) Crimea-focused EO 13685 of 19 Dec. 2014 ... and Crimea-related SDNS Near-total embargo (as for Cuba), OFAC-administered, amended most recently in Sept. 2019 Related BIS implementing rules of 29 Jan. 2015 And OFAC Sept. 2019 Crimea-related SDN designations (see slide 46) Russian export pipeline sanctions - especially against Nord Stream 2 (CAATSA section 232, NDAA 2020 and further proposed statutory measures, see slides 7-8, 53 and 62-63) CBW Act application to Russia of 2018-2019 (two rounds, see slides 64-68 - and possibly more soon, per the Navalny poisoning) - involves Treasury, Commerce and State Depts. Application of various Iran, Venezuela, Syria, and North Korea sanctions (including against some Russian companies) authorized by a web of laws and executive orders (see slides 33, 41, 43, 48 and 50 below) Bottom line: US Russia-sanctions analysis is now like peeling an ever more complex onion! Morgan Lewis 17

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