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U.S. Issues Guidance on Sanctions Relating to Russia’s Defense and Intelligence Sectors
30 October 2017
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On Friday, October 27, the U.S. Department of State issued public guidance on the implementation of Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA).
Section 231 of CAATSA requires the U.S. President to impose potential sanctions against individuals or entities that knowingly engage in “significant transactions” with persons that are a part of, or operating for or on behalf of, Russia’s defense or intelligence sectors.
The new guidance is accompanied by a list of entities considered to be operating in Russia’s defense or intelligence sectors and a discussion of when a transaction is “significant” for purposes of Section 231.
Defense- and intelligence-related transactions are more likely to be considered “significant,” while transactions with purely civilian end-uses or end-users or transactions required by law with the Federal Security Service are less likely to raise any sanctions risks.
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Satish M. Kini
Sandeep S. Dhaliwal
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