Clifford Chance

US Congress Could Enact Sweeping Sanctions Bill Against Russia, Iran, and North Korea

27 July 2017

On July 25, 2017, the US House of Representatives passed by a vote of 419-3 the "Countering America's Adversaries Through Sanctions Act". CAATSA now goes to the US Senate, which in June already passed its own version of the bill by a similar margin, 98-2, Senate Resolution 722, Countering Iran's Destabilizing Activities Act, for further action. If enacted, CAATSA will codify the current Russia/Ukraine-related sanctions as law rather than executive action, establish a mandatory Congressional review process should the President wish to lift certain Russia/Ukraine-related sanctions, as well as authorize the President to impose new sanctions against Russia, Iran, and North Korea, including "mandatory" sanctions against persons that the President determines, at his discretion, to have engaged in certain sanctionable activity. The mandatory label is somewhat misleading because if the President does not issue a determination against a particular person under the Russia/Ukraine-related sanctions, then CAATSA does not in fact mandate any action against that person.

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