In the past several days, the US Government has issued a slew of sanctions measures targeting Russia. These represent the first major escalation of sanctions against Russia under the Biden Administration and, according to a White House Fact Sheet , are stated to be in response to Russia’s “harmful foreign activities,” including efforts to undermine free and fair democratic elections and institutions, malicious cyber activities (including the recent SolarWinds incident), transnational corruption, targeting of dissidents…

On August 2, 2019, the US State Department announced targeted sanctions against Russia related to the March 2018 use of a “novichok” nerve agent in an attempt to assassinate UK citizen Sergei Skripal and his daughter Yulia Skripal in the United Kingdom.  This was the second round of sanctions required under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the “CBW Act”) following the State Department’s determination on November 6, 2018 that Russia had failed to provide reliable assurances that it would not engage in future chemical weapons attacks. The US Government issued the first round of CBW Act sanctions on August 27, 2018. See our blog post on the first round of CBW Act sanctions here.

On January 29, 2018, the US Treasury Department (“Treasury”) delivered five reports to Congress, as required under the Countering America’s Adversaries Through Sanctions Act (“CAATSA”).  Please see our prior blog post on CAATSA here.  Among these reports was a list identifying Russian senior political figures, oligarchs, and parastatal entities pursuant to CAATSA Section 241.  This report was released during the same week that other CAATSA sanctions targeting Russia have gone into effect.

On October 31, 2017, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended and reissued Directive 4 of the Ukraine/Russia-related sectoral sanctions (“Directive 4”), which targets the Russian energy sector, and updated its guidance regarding the implementation of Ukraine/Russia-related sanctions.  OFAC’s amendment and reissuance of Directive 4 was expected pursuant to Section 223(d) of Title II of the Countering America’s Adversaries Through Sanctions Act (“CAATSA” see our previous blog post on CAATSA here).  Also under CAATSA, Directive 1 and Directive 2 were amended and reissued on September 29, 2017 (see our previous blog post here).  OFAC originally published Directive 4 in September of 2014, pursuant to Executive Order 13662.  In conjunction with OFAC’s guidance, the US Department of State (“State Department”) also published guidance regarding CAATSA Sections 225 and 232.