Sec. 1241 of the FY 2021 NDAA (CAATSA Sec. 231 Determination)

Date issued: Jan. 01 2021

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TURBOFAC Commentary (94 words)


1) This section of the 2021 NDAA is a rare statutory provision that makes the sort of “significant transaction” determination that is ordinarily fully reserved to the Executive Branch. Its appearance in the bill prior to its signature by the President appears to have led to the State Department making the “significant transaction” determination itself. See The United States Sanctions Turkey Under CAATSA 231 (State Dep't Press Release). The 2021 NDAA provision remains relevant insofar as it provides that the sanctions imposed on Turkey must remain in place until certain conditions are met.