Secondary Sanctions Enforcement Announcement - Sanctions on Russian Entity and a Vessel Engaging in the Construction of Nord Stream 2 (Jan. 2021)

Date issued: Jan. 19 2021

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TURBOFAC Commentary (510 words)


1) For the criteria we normally use to determine what designation notices to include in the Research System, see Introductory Note Common to all Derivative Designation Notices Included in the Research System.

In this case, the entity sanctioned is of the country (Russia) that is the target of the sanctions provision at issue, so this designation announcement would normally be excluded from the Research System. Here, however, it is notable as the first enforcement action related to the Nord Stream 2 pipeline that is the subject to PEESA.

In this case, however, the designation was made pursuant to CAATSA, Sec. 232, which authorizes sanctions on persons that sell, “to the Russian Federation, for the construction of Russian energy export pipelines,” goods or services of which the...