The US Departments of State (State) and the Treasury (Treasury) have, in recent weeks, issued implementation guidance on the new secondary sanctions on Russia in the Countering America’s Adversaries Through Sanctions Act (CAATSA), which became law on August 2, 2017.  For a  general discussion of CAATSA, please see our previous advisory.  This advisory addresses each of CAATSA’s Russia secondary sanctions provisions covered by the State and Treasury guidance, highlighting the significant risks that non-US companies may face under CAATSA when operating in Russia or doing business with Russian individuals or entities.

For more information, please see our advisory.