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Implementing the CAATS Act: Revisions to Sectoral Sanctions Against Russia
3 October 2017
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To implement the Countering America’s Adversaries through Sanctions Act (the “CAATS Act”), the U.S. Treasury Department has amended U.S. sectoral sanctions against Russia, effective November 28, to bar U.S. persons from transactions in debt of over 14 days' maturity of designated Russian financial services firms or over 60 days' maturity of designated Russian energy firms.
President Trump concurrently issued a presidential memorandum delegating certain functions and authorities of the CAATS Act, principally to the Secretaries of State and Treasury.
Senators Cardin and McCain sent an open letter to President Trump calling for broad implementation of the CAATS Act, particularly in regard to the defense and energy sectors.
International Economic Sanctions & OFAC Compliance
White Collar & Regulatory Defense
Banking Enforcement & Litigation
Regional & Other Practices
Financial Institutions in Russia
Energy & Natural Resources in Russia
White Collar & Regulatory Defense in Europe
Satish M. Kini
Robert T. Dura
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