‘CAATSA’ - US authorities issue comprehensive implementation guidance on new sanctions law

Scott Balber (+1 917 542 7810, scott.balber@hsf.com) is a partner and Jonathan Cross (+1 917 542 7824, jonathan.cross@hsf.com) is of Counsel in the New York office of Herbert Smith Freehills.

On 31 October 2017, the US Department of State and Office of Foreign Assets Control (OFAC) posted comprehensive guidance related to the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA), write Scott Balber and Jonathan Cross of Herbert Smith Freehills. The new guidance addresses multiple provisions of CAATSA, mainly those concerning secondary sanctions targeting Russia; it also significantly limits and clarifies the scope of these secondary sanctions.