U.S. Issues Guidance on New Russian Sanctions
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- Last week, the U.S. Departments of State and Treasury issued new guidance on the implementation of recent legislation imposing sanctions against Russia.
- The guidance pertains mostly to new “secondary sanctions,” which seek to discourage non-U.S. persons from engaging in certain targeted activities with or involving Russia.
- The guidance defines several key terms and narrows the potential scope of several provisions, removing some uncertainty regarding how the U.S. government intends to apply these new sanctions.