Morgan Lewis US and Russia Sanctions Update
Basic Framework - US/EU/UK (cont'd)
CAATSA enacted August 2017 (and State / Treasury Guidelines of Oct. 2017) - and see:
Full summary discussion at slides 46-59
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The Jan. 2018 CAATSA-based Reports/Lists for Congress (see slides 55-56)
And note the Sept. 2018 CAATSA-implementing EO (see slide 56), and proposed DASKA Act would
further broaden CAATSA (see slides 6 and 69) ... and CAATSA sec. 232 scope expansion (see slides 8
and 52)
Various cyber- and defense-related CAATSA secondary-sanctions designations of Russian / other
foreign entities to date (see slides 40-42 and 50-51)
Crimea-focused EO 13685 of 19 Dec. 2014 ... and Crimea-related SDNs
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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 45)
Russian export pipeline sanctions - especially against Nord Stream 2 (CAATSA section 232,
NDAA 2020 and 2021 etc., see slides 7-8, 52 and 60-62)
CBW Act application to Russia of 2018-2019 (two rounds, see slides 63-68) - and now 2021
too (per the Navalny poisoning etc.) – 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,
40, 42, 47 and 49 below)
Bottom line: US Russia-sanctions analysis is now like peeling an ever more complex onion!
Morgan Lewis
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