On December 19, 2018, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) submitted a letter to congressional leaders (“Congressional Letter”) notifying Congress of its intent to terminate the sanctions imposed on En+ Group plc (“En+”), UC Rusal plc (“RUSAL”), and JSC EuroSibEnergo (“ESE”) in 30 days. On the same day, OFAC announced new sanctions against a number of individuals and entities for their involvement in a range of malign activities. Concurrently, the US Department of State announced it had added 12 individuals and entities to the List of Specified Persons under Section 231 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) for being part of, or operating for or on behalf of, the defense or intelligence sector of the Russian Federation.
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.
Today, the President signed into law the “Countering America’s Adversaries Through Sanctions Act” (“CAATSA”), a bill that he called “seriously flawed” in a statement about CAATSA issued at the same time he signed the bill.
On July 27, 2017, the US Senate approved in a 98-2 vote H.R. 3364, the “Countering America’s Adversaries Through Sanctions Act” (“H.R. 3364”). We previously summarized H.R. 3364 in our blog posts here and here. H.R. 3364 now goes to the White House where the President will have 10 days to (1) sign the bill, (2) veto the bill, or (3) permit the bill to become law without his signature. The 10-day clock will start when the US Congress delivers H.R. 3364 to the President, which may happen in a few days.