On 24th September, the European Sanctions Blog provided a useful update on developments re certain CAATSA-related sanctions with respect to the Russian Federation.  The Secretary of State has added 33 additional persons to the section 231(d) CAATSA list of those “being a part of, or operating for or on behalf of, the defense or intelligence sectors of the [Russian government]”there now being 72 names on the list, 39 having been listed in October 2017. Being listed does not itself impose sanctions, but any person who knowingly engages in a “significant transaction” with any of the identified persons will be subject to mandatory sanctions, the blog says.

The list of 72 names can be found at –

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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