Morgan Lewis US and Russia Sanctions Update
Proposed Further US Laws
See slide 6 for newest proposed additional sanctions law as of early 2021
DASKA Act (DASKAA)
Dec. 2019 amended draft approved by Senate Foreign Relations Committee; and Senate
sponsors' 18 Dec. 2019 statement, and State Dept's 17 Dec. 2019 letter stating
Administration's opposing views
As of fall 2020 some renewed focus on possibly moving it forward to enactment - though
nothing more on this yet in 2021
Would amend/enlarge CAATSA in various ways (incl. enlarging scope of possible secondary
sanctions - applicable to non-US persons)... including mandating sanctions against:
Russian malicious cyber activities; shipbuilding industry; individuals and parastatal entities thought to
be close to President Putin (and their family members, and financial institutions engaging in significant
transactions with them)
a wide range of Russian domestic energy projects, and global energy projects involving certain Russian
companies, including
making investments in LNG "export facility located outside of [Russia]" (with low $ thresholds)
making investments in energy project (unclear meaning) outside Russia that also has involvement by a
Russian parastatal or state-owned/controlled company (where total value of project is >$250 million)
that sell, lease, provide to Russia goods, services, technology, financing or support that could
directly/significantly contribute to Russia's ability to develop/produce crude oil resources in Russia
(including with respect to associated infrastructure)
excludes maintenance of existing projects
USG to issue guidance as to (i) scope/application of the exception, and (ii) listing specific covered goods, services,
technology, financing, support
US persons' dealing in Russian sovereign debt (this would expand the current limited CBW Act ban re
Russia's sovereign debt - see slide 67)
Menu of possible sanctions is from existing CAATSA (mainly re commerce in/with US)
Morgan Lewis
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