On 3rd June, Morrison Foerster published a Client Alert which says that Congress now considering no fewer than 5 Russia-focused sanctions Bills.  The latest explicitly threatens the Nord Stream 2 gas pipeline project, sanctions against which the Energy Secretary says are inevitable.  That said, the already enacted CAATSA included a provision that allowed the Administration to target certain high-value investments or sales for the construction of Russian energy export pipelines – but this is discretionary, and the State Department has indicated that only projects initiated after CAATSA’s enactment would be subject to sanctions, thereby effectively excluding Nord Stream 2.  The Alert says that the firm’s National Security team prepared a brief primer on each Bill, with the caveats that additional Bills and amendments are likely forthcoming and the legislative timeline remains unclear.  The Bills already tabled include those targeting further the energy sector (at least ostensibly to protect Europe’s energy supplies), defending future elections from foreign interference, and Russian “aggression” in various areas, including in cyberspace.


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

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s