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Happy new year everyone. The government is shut down, but there has already been a flurry of activity in 2019 on the economic sanctions and embargoes front. Here is a summary of where we stand on various sanctions regimes.

Russia. On January 10, 2019, the Trump administration defended its decision to ease U.S. sanctions against companies connected to the Russian oligarch Oleg Deripaska. In 2017, the “Countering America’s Adversaries Through Sanctions Act” (CAATSA) passed Congress overwhelmingly and was signed into law by President Trump. As we blogged here and here, CAATSA codified strict Russia sanctions. It also allows Congress to block any termination of sanctions by the Executive. In December 2018, the Treasury department announced that it would lift sanctions on three of Deripaska’s companies: EN+ group, Rusal, and JSC EuroSibEnergo. Though Deripaska would continue to be subject to sanctions personally, Secretary Mnuchin reportedly told members of Congress in a briefing that the three companies had committed to “significantly diminish Deripaska’s ownership and sever his control.” Many lawmakers left the briefing unimpressed, and expressed concern that lifting sanctions would result in a tremendous financial benefit to Deripaska, whose designation by Treasury for sanctions last year reads like a mafia indictment. For now, it is unlikely that Congress is united enough to use its CAATSA powers to maintain the sanctions in the face of the Administration’s decision to lift them. But it is clear that Congressional Democrats intend to exercise their oversight powers when it comes to sanctions (or lack thereof) against Russia.
Continue Reading New Year Sanctions Roundup: Where Do We Stand?

Since the U.S. Government determined that Russia interfered in the 2016 election[1], movement around Russia sanctions policy has been vigorous, if not unidirectional. In 2016, the United States implemented twice sanctions against Russia: In September, dozens of individuals and entities were sanctioned with regards to Russian operations in Crimea. In December, President Obama expelled 35 Russian intelligence agents from the U.S. and imposed sanctions on two major intelligence services, as a response to those interferences from Russia. In 2017, concerned that the new Administration might roll back certain sanctions on Russia, Congress overwhelmingly passed the Countering America’s Adversaries Through Sanctions Act, codifying and adding to sanctions on Russia already in place (which we reported on here).

In January, we anticipated two more moves mandated under CAATSA: 1) the publication of a List of Senior Political Figures and Oligarchs in the Russian Federation and 2) sanctions against entities and individuals that had conducted significant transactions with the defense and intelligence sectors in Russia. It appears that one was a feint and the other, a flop.
Continue Reading Lurches, Leaps, Feints, and Flops: Movements Without Motion in Russian Sanctions Policy

On July 17, 2017, the U.S. State Department certified that Iran continues to meet the conditions of the Iran nuclear agreement known as the Joint Comprehensive Plan of Action, or JCPOA. As a result, for the next 90 days, the United States will maintain significant reductions in its sanctions against Iran as provided in the JCPOA. Among other things, those provisions allow non-U.S. companies to do business in Iran. The State Department’s action signals that for now, State believes that the JCPOA is the right U.S. policy toward Iran.
Continue Reading One Year From Now, You May Be Out of Iran: Trump Administration Policy and the Timeline for Snapback