Report to Congress on Provision of Pipe-Laying Vessels and Activities for Certain Russian Energy Export Pipelines (PEESA)

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TURBOFAC Commentary (214 words)

Notes:

1) As described publicly at Secondary Sanctions Enforcement Announcement - Nord Stream 2 and European Energy Security (May 19, 2021), this is a very rare “national interest waiver”. (See Sec. 7503(f) of the for FY 2020 (PEESA), as amended by Sec. 1242 of the NDAA for FY 2021. The waiver provision provides as follows:

(f) National Interest Waiver.—The President may waive the application of sanctions under this section with respect to a person if the President—
(1) determines that the waiver is in the national interests of the United States; and
(2) submits to the appropriate congressional committees a report on the waiver and the reasons for the waiver.

The waiver (p. 9 et seq. of PDF file) is notable for the rationale provided. Essentially, it boils down to 'the allied governments...

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Report to Congress on Provision of Pipe-Laying Vessels and Activities for Certain Russian Energy Export Pipelines (PEESA)

TURBOFAC Commentary (214 words)