As required under Section 241 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), last night the U.S. government released a public, unclassified version of the much-anticipated “Kremlin Report.”  The report was intended to ‘name and shame’ Russian political and business leaders, list their assets outside of Russia, provide an index of corruption with respect to the listed individuals, determine estimated net worth of the listed parties, and analyze the impact of imposing sanctions on listed parties. View Full Post
Under Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), the Trump administration was due to issue secondary sanctions on non-U.S. persons that conduct significant transactions with Russia’s defense and intelligence sectors.  The Trump administration declined to issue those new sanctions, claiming that CAATSA was serving as an effective deterrent – discouraging non-U.S. View Full Post
Many companies supply goods and services through third party distributors.  When well-structured, the use of distributors can shift some of the cost and compliance risk of selling products outside of your home territory.  But distributors can also create sanctions liability for companies, especially when foreign subsidiaries or others within the company are in on the bad acts. View Full Post
Last Friday the State Department belatedly released a list of 39 Russian entities that operate as part of Russia’s defense and intelligence sectors (the full list is below).  Congress required the Trump Administration to produce a list of such parties as part of the Countering America’s Adversaries Through Sanctions Act (CAATSA), which became law in August 2017.  View Full Post