Certification of Good Faith Wind Down Efforts and Wind-Down Explanation of Decision (PEESA)

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TURBOFAC Commentary (210 words)

Notes:

1) Section 1242(f) of the the FY 2021 (Amending the "Protecting Europe's Energy Security Act of 2019”).

(f) Wind-Down Period.—The President may not impose sanctions with respect to a person identified in the first report submitted under section 7503(a) of the Protecting Europe’s Energy Security Act of 2019, as amended by this section, after the date of the enactment of this Act for operations subject to sanctions by reason of the amendments made by this section if the President certifies in that report that the person has, not later than 30 days after such date of enactment, engaged in good faith efforts to wind down such operations.

Section 1242 provided for secondary sanctions the be applied on any entity that "provided for [] vessels [involved in the construction of NordStream 2] underwriting services or insurance...

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Certification of Good Faith Wind Down Efforts and Wind-Down Explanation of Decision (PEESA)

TURBOFAC Commentary (210 words)