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Russia Sanctions to be Expanded

Friday, August 10, 2018
Sandler, Travis & Rosenberg Trade Report

The State Department has announced the impending adoption of additional sanctions on Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 following a determination that the Russian government has used chemical or biological weapons against international law or against their own nationals. The U.S. will consider a second tranche of sanctions if Russia does not meet a series of criteria within 90 days.

The State Department indicates that additional sanctions will be imposed in a number of respects, including by imposing a presumption of denial for all national security sensitive goods or technologies that are controlled by the Department of Commerce pursuant to the Export Administration Regulations. These goods are currently subject to a license but when the sanctions go into effect the DOC will be presumptively denying such applications.

The State Department will issue a Federal Register notice on or around Aug. 22 detailing these sanctions. The sanctions will ostensibly include a number of carve-outs, including waivers with respect to space flight activities, to ensure the safety of commercial passenger aviation, as well as for the provision of foreign assistance to Russia and the Russian people.

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