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.” |