US Sectoral Sanctions
CBW Act Sanctions
History/first round - August 2018
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Adopted under the Chemical and Biological Weapons Control and Warfare Elimination
Act of 1991 (the "CBW Act") and related EO 12851 of June 1993
First announced by State Dep't Determinations notice in Aug./Sept. 2018
Triggered by finding that the Russian gov't was responsible for the Skripal poisoning by
Novichok in England in March 2018 (which Russia continues to deny)
The first round of these new sanctions went into effect immediately in Aug. 2018 - with
certain exceptions/waivers (per State Dep't finding that such are essential to US national
security interests) – namely:
a ban on foreign assistance, arms sales and related financing (with exception granted for gov't
space cooperation and commercial space launches), and denial of US gov't credit / guarantees /
other financial assistance
and a ban on exports/reexports of national security-sensitive goods and technology to Russia
these being items designated as "NS 1" or "NS 2" on the Commerce Control List ("CCL" – Supp. No. 1 to
Part 740 of EAR), all of which previously had been exportable with license for Russia
there are many such items - spanning the whole CCL: nuclear materials, facilities and equipment; special
materials, equipment, chemicals, microorganisms, toxins etc.; materials processing; electronics;
computers; technology and information security; sensors and lasers; navigation and avionics; marine; and
aerospace/propulsion
Morgan Lewis
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