The Countering America’s Adversaries Through Sanctions Act (CAATSA) was signed into law by President Trump on August 2, 2017. This put in motion several deadlines, three of which are due next Monday, January 29, 2018.

Based on past experience, the Trump administration may not meet these deadlines. Nonetheless, it is clear that the impact of these sanctions will be felt differently by different sectors of the U.S. economy. This is an opportunity for industries to participate in a dialogue with State and the key sanctions architects to seek ways to mitigate the disruption of any sanctions while preserving their intended effect on Russian interests.

Section Title Action
231 Imposition Of Sanctions With Respect To Persons Engaging In Transactions With The Intelligence Or Defense Sectors Of The Government Of The Russian Federation. 231(a) states, “The President shall impose five or more of the sanctions described in section 235 with respect to a person the President determines knowingly, on or after such date of enactment, engages in a significant transaction with a person that is part of, or operates for or on behalf of, the defense or intelligence sectors of the Government of the Russian Federation, including the Main Intelligence Agency of the General Staff of the Armed Forces of the Russian Federation or the Federal Security Service of the Russian Federation.”

 

Section Title/Responsible Agency Summary
241 Report On Oligarchs And Parastatal Entities Of The Russian Federation.

This report is to be submitted by the Secretary of the Treasury in consultation with the Director of National Intelligence and the Secretary of State.

241(a)(1) – (a)(5) describe the required elements of the report:

·         The identification and assessment of senior foreign political figures and oligarchs in the Russian Federation;

·         An assessment of Russian parastatal entities;

·         The exposure of key U.S. economic sectors to these entities;

·         The likely effects of imposing debt and equity restrictions on parastatal entities, as well as adding them to Treasury’s Specially Designated Nationals and Blocked Persons List (SDN); and

·         The potential impacts of imposing secondary sanctions on persons or entities identified in this report.

 

Section Title/Responsible Agency Summary
243 Report On Illicit Finance Relating To The Russian Federation.

This report is to be submitted by the Secretary of the Treasury in consultation with the Director of National Intelligence and the Secretary of State.

243(a) states this report will describe “in detail the potential effects of expanding sanctions under Directive 1 (as amended), dated September 12, 2014, issued by the Office of Foreign Assets Control under Executive Order No. 13662 (79 Fed. Reg. 16169; relating to blocking property of additional persons contributing to the situation in Ukraine), or any successor directive, to include sovereign debt and the full range of derivative products.”

 

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Photo of Carlton Greene Carlton Greene

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering…

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.

Photo of Dj Wolff Dj Wolff

David (Dj) Wolff is a partner and attorney at law in the firm’s Washington, D.C. and London offices and a director with C&M International, the firm’s trade policy affiliate.

At Crowell & Moring, he practices in the International Trade Group, where his practice…

David (Dj) Wolff is a partner and attorney at law in the firm’s Washington, D.C. and London offices and a director with C&M International, the firm’s trade policy affiliate.

At Crowell & Moring, he practices in the International Trade Group, where his practice covers compliance with U.S. economic sanctions, export controls and antiboycott regimes, and anti-money laundering (AML) laws and regulations. He is experienced in providing day-to-day compliance guidance, developing compliance programs including through on-site compliance trainings, responding to government inquiries, conducting internal investigations, representing them during civil and criminal enforcement proceedings, and, in collaboration with colleagues, managing the potential conflict of laws that can arise from the interaction between extraterritorial impacts of U.S. regulations and third country “blocking” laws or data privacy regulations. Dj splits his time between Washington and London, working regularly with European clients and colleagues to provide coordinated guidance on U.S., U.K., and EU sanctions compliance and enforcement. Dj also has extensive experience in international mergers and acquisitions, advising both buyers and sellers regarding the international trade implications of a potential deal.