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New Chemical Weapons Sanctions Against Russia Could Have Far-Ranging Effects
21 August 2018
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On August 6, 2018, the U.S. Department of State determined that Russia used chemical or biological weapons against Sergei and Yulia Skripal, which triggers two rounds of sanctions under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the “CBW Act”) against Russia.
The first tranche of sanctions will include, among others, a ban on exports to Russia of security-sensitive goods and technology. The second tranche, taking effect if Russia does not comply with certain criteria under the CBW Act, may include prohibition of U.S. exports to Russia, restrictions on the importation into the U.S. of Russian articles, downgrading or suspension of diplomatic relations between the U.S. and Russia and revocation of the authority of Russian state air carriers to provide transportation in the U.S.
Companies trading with Russia and Russian companies engaged in cross-border transactions should consider reviewing their contracts for any contractual implications of the CBW Act sanctions.
Satish M. Kini
Dmitry A. Karamyslov
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