Imposition of Sanctions in Connection with Nord Stream 2 (Aug. 2021), Imposition of Further Sanctions in Connection with Nord Stream 2 (Nov. 22, 2021)

Date issued: Nov. 22 2021

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TURBOFAC Commentary (470 words)

Notes:

1) Read in conjunction with Sanctions on Russian Entity and a Vessel Engaging in the Construction of Nord Stream 2 (Jan. 2021) and Secondary Sanctions Enforcement Announcement - Nord Stream 2 and European Energy Security (May 19, 2021), and see Executive Order on Blocking Property with Respect to Certain Russian Energy Export Pipelines (E.O. 14039) (and comments thereto).

Given that PEESA (and the related EO) is a Russia-focused sanctions authority, one could argue that there is yet to be a PEESA-related designation that qualifies as a genuine "secondary sanctions" enforcement action (i.e. the sanctioning of a person in connection with an international trade transaction, where the person sanctioned is not of the target country). For the criteria we normally...