On 15 July, the US State Department advised that it had updated the public guidance for Section 232 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), which allows for the imposition of sanctions on persons making certain investments or engaging in certain other activities with respect to Russian energy export pipelines. Implementation will now include investments or other activities related to a broader scope of Russian energy export pipelines, including Nord Stream 2 and the second line of TurkStream. Persons making such investments or engaging in such activities, including but not limited to financing partners, as well as pipe-laying vessels and related engineering service providers engaging in the deployment of the pipelines, may be subject to sanctions. While the State Department says that it is not imposing any sanctions at this time, it warns that, if it determines that the imposition of sanctions is it will not hesitate to do so. It therefore says that it encourages companies to reassess their participation in Russian energy export pipelines, and to take appropriate steps to mitigate their exposure to sanctions.
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