On Tuesday, October 31, the U.S. Departments of State and Treasury issued new guidance the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) relating to sanctions against Russia. This is in addition to guidance that the State Department previously issued on CAATSA Section 231.
Amendments to Directive 4
Section 223(d) of CAATSA directed the Treasury Department to expand the scope of Directive 4 of the Sectoral Sanctions Identifications (“SSI”) List, which governs the provision of goods and services by U.S. persons to certain types of oil projects. The new restrictions are effective January 29, 2018.
Currently, the restrictions apply only to … Read more