US Sectoral Sanctions
CBW Act Sanctions (cont'd)
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Per the CBW Act, if Russia hadn't met the following three conditions by 90 days after
the initial determination (so, in Nov. 2018), as certified by the President to Congress:
... that the RF gov't (i) is no longer using chemical/biological weapons etc.; (ii) has
provided reliable assurances that it won't do so in future; and (iii) is willing to allow
relevant on-site inspections by UN or other internationally recognized impartial
observers etc. to confirm same
This of course didn't happen (indeed, the State Dep't in Nov. 2018 notified Congress
that Russia ignored the deadline)
So the President (in consultation with Congress) was 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 Russial
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
Morgan Lewis
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