Worldwide: U.S. Sanctions On Russia - Latest And Possible Additional Measures


Building on prior extensive Russia-related sanctions, the U.S. government has further sanctioned Russia by intensifying controls on exports and reexports to the country. Alone, this step is unlikely to affect major volumes of U.S.-Russia commerce. However, possible additional sanctions could be much more far-reaching.

Description of New Sanctions and Possible Additional Sanctions

CBW Act Sanctions

On August 27, 2018, new export control sanctions imposed by the United States on Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the "CBW Act") came into effect. 

The sanctions implement the U.S. State Department's August 6, 2018 determination that the Russian government used chemical weapons in violation of international law or lethal chemical weapons against its own nationals. The alleged violation is sanctionable under the CBW Act. Whether the U.S. government imposes additional sanctions under the CBW Act and if so, the character of those sanctions will depend on the U.S. government's findings on corrective and cooperative measures by the Russian government within the next three months.

Initial round of CBW Act sanctions:  The principal U.S. export control agency, the Commerce Department's Bureau of Industry and Security ("BIS"), is generally to deny applications for licenses to export or reexport goods, software and technology to Russia under the Export Administration Regulations (the "EAR"). BIS is not expanding the scope of items that are export-licensable to Russia. The exporters can continue to rely on applicable license exceptions set forth in the regulations. In addition, standard case-by-case licensing is preserved for exports and reexports of goods pursuant to new licenses for (i) goods relating to safety of commercial passenger aviation; (ii) deemed exports and reexports to Russian nationals; (iii) exports to wholly owned U.S. subsidiaries in Russia; (iv) exports in support of government space cooperation and commercial space launches; and (v) exports to commercial end users for civilian end uses.

Other initial sanctions include termination of arms sales to Russia and termination of licenses for the export to Russia of defense-related articles and services, except in support of government space cooperation and commercial space launches, where licensing shall continue on a case-by-case review basis. The U.S. government has also undertaken to terminate foreign military financing and to deny any credit, credit guarantees, or other financial assistance by any U.S. government agency (including by the Export-Import Bank) to Russia.

Possible second round of CBW Act sanctions:  As specified by the CBW Act, the U.S. government may impose additional sanctions against Russia. If the additional sanctions are imposed, the CBW Act generally requires them to include at least three of the following: (i) opposition by the U.S. government of extension of any loan or financial or technical assistance to Russia by international financial institutions; (ii) prohibition for any U.S. Bank to make any loan or provide any credit to the Russian government, except with respect to the purchase of food or other agricultural commodities or products; (iii) export prohibition of all other goods and technology to Russia, excluding food and other agricultural commodities and products; (iv) import restrictions of products grown, produced or manufactured in Russia (which may include petroleum or any petroleum product); (v) downgrading or suspending diplomatic relations between the United States and Russia; and/or (vi) suspension of the authority of the Russian state-owned or- controlled- air carriers to transport to or from the United States, notwithstanding any agreement relating to air services, or termination of such agreement, resulting in the revocation of such authority.

Congressional Proposals

In the wake of the 2017 Countering America's Adversaries Through Sanctions Act of August 2017 (the "CAATSA"), the U.S. Congress is considering proposals to further expand statutorily mandated sanctions against Russia. The principal current proposal is the Defending American Security from Kremlin Aggression Act (the "DASKAA"). The DASKAA, if adopted, would:

  • prescribe a series of immediate sanctions –
    • blocking of major Russian state-owned banks – Vnesheconombank, Sberbank, VTB Bank, Gazprombank, Bank of Moscow, Rosselkhozbank, or Promsvyazbank (the "Banks") – which would generally ban all direct and indirect commercial interaction with U.S. persons; and
    • ban on U.S. persons executing investment in and other dealings with the Russian government's issued bonds, foreign exchange swap agreements, and any other financial instrument that represents Russian sovereign debt – including the Banks.
  • mandate sanctions on persons (i) knowingly carrying out transactions worth $1 million or more (or $5 million or more during a 12-month period) pertaining to goods and services that support Russia's crude oil resources development, on or after 180 days after the enactment of the DASKAA, or (ii) investing in energy projects worth $250 million outside of Russia that are supported by Russian state-owned or state-controlled entities, on or after the enactment of the DASKAA.

Other measures could include blocking measures with respect to persons whom the U.S. government finds facilitate illicit and corrupt activities on behalf of the Putin administration, and persons, including financial institutions, engaging in significant transactions with such persons.

The DAASKA remains under consideration by the U.S. Senate Committee on Foreign Relations. Some sources indicate that adopting the DASKAA, as currently drafted, is unlikely. Even if the Congress does not pass the DASKAA, there is a good chance that the Congress will pass portions of it and other Russia-sanctions proposals as portions of one or more other bills.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

Events from this Firm
28 Aug 2019, Webinar, San Francisco, United States

This CLE webinar will analyze the potential antitrust ramifications of joint ventures (JVs) and other collaborations between competitors and how to balance the pro-competitive efficiencies against the anti-competitive effects of a proposed JV.

1 Oct 2019, Other, Washington, DC, United States

Orrick is proud to host the AIPN for its final breakfast meeting of 2019 for a session titled “Helping the World Gasify”. As natural gas production and use is very unevenly distributed throughout the world, often gas produced in association with crude oil is sold below cost or flared.

25 Nov 2019, Speaking Engagement, New York, United States

Lorraine McGowen will be speaking on the upcoming “Evaluating the Financial Health of an Entity” panel at the New York session of the Pocket MBA: Finance for Lawyers and Other Professionals program, hosted by the Practising Law Institute.

Similar Articles
Relevancy Powered by MondaqAI
Sheppard Mullin Richter & Hampton
In association with
Related Topics
Similar Articles
Relevancy Powered by MondaqAI
Sheppard Mullin Richter & Hampton
Related Articles
Related Video
Up-coming Events Search
Font Size:
Mondaq on Twitter
Mondaq Free Registration
Gain access to Mondaq global archive of over 375,000 articles covering 200 countries with a personalised News Alert and automatic login on this device.
Mondaq News Alert (some suggested topics and region)
Select Topics
Registration (please scroll down to set your data preferences)

Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice):

  • To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
  • To enable features such as password reminder, news alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our content providers ("Contributors") who contribute Content for free for your use.

Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Mondaq has a "free to view" business model. Our services are paid for by Contributors in exchange for Mondaq providing them with access to information about who accesses their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.

Details of each Contributor to which your personal data will be transferred is clearly stated within the Content that you access. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.

Please indicate your preference below:

Yes, I am happy to support Mondaq in maintaining its free to view business model by agreeing to allow Mondaq to share my personal data with Contributors whose Content I access
No, I do not want Mondaq to share my personal data with Contributors

Also please let us know whether you are happy to receive communications promoting products and services offered by Mondaq:

Yes, I am happy to received promotional communications from Mondaq
No, please do not send me promotional communications from Mondaq
Terms & Conditions (the Website) is owned and managed by Mondaq Ltd (Mondaq). Mondaq grants you a non-exclusive, revocable licence to access the Website and associated services, such as the Mondaq News Alerts (Services), subject to and in consideration of your compliance with the following terms and conditions of use (Terms). Your use of the Website and/or Services constitutes your agreement to the Terms. Mondaq may terminate your use of the Website and Services if you are in breach of these Terms or if Mondaq decides to terminate the licence granted hereunder for any reason whatsoever.

Use of

To Use you must be: eighteen (18) years old or over; legally capable of entering into binding contracts; and not in any way prohibited by the applicable law to enter into these Terms in the jurisdiction which you are currently located.

You may use the Website as an unregistered user, however, you are required to register as a user if you wish to read the full text of the Content or to receive the Services.

You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these Terms or with the prior written consent of Mondaq. You may not use electronic or other means to extract details or information from the Content. Nor shall you extract information about users or Contributors in order to offer them any services or products.

In your use of the Website and/or Services you shall: comply with all applicable laws, regulations, directives and legislations which apply to your Use of the Website and/or Services in whatever country you are physically located including without limitation any and all consumer law, export control laws and regulations; provide to us true, correct and accurate information and promptly inform us in the event that any information that you have provided to us changes or becomes inaccurate; notify Mondaq immediately of any circumstances where you have reason to believe that any Intellectual Property Rights or any other rights of any third party may have been infringed; co-operate with reasonable security or other checks or requests for information made by Mondaq from time to time; and at all times be fully liable for the breach of any of these Terms by a third party using your login details to access the Website and/or Services

however, you shall not: do anything likely to impair, interfere with or damage or cause harm or distress to any persons, or the network; do anything that will infringe any Intellectual Property Rights or other rights of Mondaq or any third party; or use the Website, Services and/or Content otherwise than in accordance with these Terms; use any trade marks or service marks of Mondaq or the Contributors, or do anything which may be seen to take unfair advantage of the reputation and goodwill of Mondaq or the Contributors, or the Website, Services and/or Content.

Mondaq reserves the right, in its sole discretion, to take any action that it deems necessary and appropriate in the event it considers that there is a breach or threatened breach of the Terms.

Mondaq’s Rights and Obligations

Unless otherwise expressly set out to the contrary, nothing in these Terms shall serve to transfer from Mondaq to you, any Intellectual Property Rights owned by and/or licensed to Mondaq and all rights, title and interest in and to such Intellectual Property Rights will remain exclusively with Mondaq and/or its licensors.

Mondaq shall use its reasonable endeavours to make the Website and Services available to you at all times, but we cannot guarantee an uninterrupted and fault free service.

Mondaq reserves the right to make changes to the services and/or the Website or part thereof, from time to time, and we may add, remove, modify and/or vary any elements of features and functionalities of the Website or the services.

Mondaq also reserves the right from time to time to monitor your Use of the Website and/or services.


The Content is general information only. It is not intended to constitute legal advice or seek to be the complete and comprehensive statement of the law, nor is it intended to address your specific requirements or provide advice on which reliance should be placed. Mondaq and/or its Contributors and other suppliers make no representations about the suitability of the information contained in the Content for any purpose. All Content provided "as is" without warranty of any kind. Mondaq and/or its Contributors and other suppliers hereby exclude and disclaim all representations, warranties or guarantees with regard to the Content, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. To the maximum extent permitted by law, Mondaq expressly excludes all representations, warranties, obligations, and liabilities arising out of or in connection with all Content. In no event shall Mondaq and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use of the Content or performance of Mondaq’s Services.


Mondaq may alter or amend these Terms by amending them on the Website. By continuing to Use the Services and/or the Website after such amendment, you will be deemed to have accepted any amendment to these Terms.

These Terms shall be governed by and construed in accordance with the laws of England and Wales and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales to settle any dispute which may arise out of or in connection with these Terms. If you live outside the United Kingdom, English law shall apply only to the extent that English law shall not deprive you of any legal protection accorded in accordance with the law of the place where you are habitually resident ("Local Law"). In the event English law deprives you of any legal protection which is accorded to you under Local Law, then these terms shall be governed by Local Law and any dispute or claim arising out of or in connection with these Terms shall be subject to the non-exclusive jurisdiction of the courts where you are habitually resident.

You may print and keep a copy of these Terms, which form the entire agreement between you and Mondaq and supersede any other communications or advertising in respect of the Service and/or the Website.

No delay in exercising or non-exercise by you and/or Mondaq of any of its rights under or in connection with these Terms shall operate as a waiver or release of each of your or Mondaq’s right. Rather, any such waiver or release must be specifically granted in writing signed by the party granting it.

If any part of these Terms is held unenforceable, that part shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties, and the Terms shall continue in full force and effect.

Mondaq shall not incur any liability to you on account of any loss or damage resulting from any delay or failure to perform all or any part of these Terms if such delay or failure is caused, in whole or in part, by events, occurrences, or causes beyond the control of Mondaq. Such events, occurrences or causes will include, without limitation, acts of God, strikes, lockouts, server and network failure, riots, acts of war, earthquakes, fire and explosions.

By clicking Register you state you have read and agree to our Terms and Conditions