Frequently Asked Questions on PEESA, as amended by the National Defense Authorization Act for FY2021

Date issued: Apr. 09 2021

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TURBOFAC Commentary (136 words)

Notes:

1) These "FAQ" provide virtually nothing in the way of notable guidance. The text of the preface and the FAQs themselves restate PEESA, as amended, without interpreting any of the legal provisions. For comments on PEESA generally, see Sec. 7503 of the NDAA for FY 2020 (PEESA), as amended by Sec. 1242 of the NDAA for FY 2021 (text incorporating amendments). To the degree that the last sentence of the third FAQ is meant to signal that the USG intends on exercising the PEESA authorities, compare Nord Stream 2 and Potential Sanctionable Activity.

2) Read in conjunction with Protecting Europe’s Energy Security Act (State Dep't FAQs - October 2020), which answers the question "How does the...