Countering America's Adversaries Through Sanctions Act (CAATSA), [Selected Russia-related provisions]

Date issued: Aug. 02 2017

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TURBOFAC Commentary (907 words)

Notes:

*See generally the RUSSIA SECONDARY SANCTIONS COMPARISON TABLE for a sanction-by-sanction breakdown of all Russia-related "secondary sanctions" and "tier 2 designation criteria" that, in practice, operate much like secondary sanctions. The table contains sanction-by-sanction comments, along with commentary on the relationships between sanctions with significant substantive overlap.

1) As it relates to topics directly implicating ordinary sanctions compliance issues, the Russia-related portion of CAATSA i) amends UFSA, ii) amends SSIDES, iii) required changes to the Sectoral Sanctions List Directives, and iv) contains a variety of other stand-alone sanctions implemented in Executive Order 13849 of September 20, 2018 (Authorizing the Implementation of Certain Sanctions Set Forth in the Countering America's Adversaries Through Sanctions Act). The CAATSA-related division of labor between OFAC, the Department of State and other agencies was set out in...