US Sectoral Sanctions
Export Pipeline Sanctions
PEESCA / NDAA 2021 (see summary at slide 7) pending - further expansion of
existing NDAA 2020 Nord Stream 2 (and TurkStream 2) sanctions
NDAA 2020 (section 7503, pp. 2637-2646) as relates to Russian export pipelines
PEESA) essential contents
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Required Administration report to Congress within 60 days of enactment (i.e., in mid-Feb.
2020), and then each 90 days thereafter, identifying: (a) vessels involved in pipe-laying (at
depth of >100 feet) for NS2, TurkStream (though the first line of that project (TurkStream
1) was then already complete), or any successor project to either; (b) foreign persons that
knowingly have (i) sold, leased, provided those vessels, or (ii) facilitated deceptive or
structured transactions to provide such vessels
President shall (upon the first 60-day report date) exercise powers to block all
property/interests in the US etc. of any company that is in violation of the requirements as
of 20 Dec. 2019 enactment date (and so on thereafter) - subject to wind-down, exceptions
and waiver provisions (see next slide)
And exclude corporate officers and controlling shareholders of the above from entry into the
US (or other involved foreign persons), and possible related blocking of property/interests
No sanctions yet levied under this new law (no new pipe-laying has begun yet as of early
Dec. 2020 though may soon resume)
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Morgan Lewis
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