On 27 October, the always-worth-reading EU Sanctions Blog reported that the State Department has published 2 new FAQ on potential secondary sanctions on vessels involved in the Nord Stream 2 and TurkStream pipeline projects.  The post says that guidance is provided on how the State Department will interpret the term “knowingly provide[d] those vessels for the construction of such a project” and clarifies when foreign people/firms engaging in sanctionable conduct will, in fact, become subject to sanctions.

I had omitted the following link (as it did not seem to generate much interest!), but it seemed time to add it again and say that, if you would like to make a (polite) gesture and help me with my removal and computer costs, I have a page 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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