On September 29, 2017, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended and reissued Directive 1 and Directive 2 implementing US sectoral sanctions targeting Russia pursuant to the Countering America’s Adversaries Through Sanctions Act (“CAATSA”). The maturity of prohibited “new debt” under Directive 1 will be reduced to 14 days (from 30 days) and the maturity of prohibited “new debt” under Directive 2 will be reduced to 60 days (from 90 days).
On July 11, 2017, President Trump signed an Executive Order allowing additional time to consider actions by the Government of Sudan before lifting US sanctions on Sudan (“July Executive Order”).
In the midst of the ongoing Department of Justice investigation into the Trump campaign ties with Russian officials, on June 15, 2017, the US Senate voted 98-2 to pass a comprehensive Russia sanctions package. These measures were offered as an amendment to, and largely overshadowed, separate Iran sanctions legislation – the Countering Iran’s Destabilizing Activities Act of 2017 (S. 722).
On April 18, 2017, the US Department of State notified the US Congress that Iran has been complying with the conditions of the Joint Comprehensive Plan of Action (“JCPOA”). The US Department of State is required to notify the US Congress every 90 days on Iran’s compliance with the JCPOA, and the April 18, 2017, notification was the first such notification under the Trump Administration.