On 2 August 2017, the President signed into law the Countering America’s Adversaries Through Sanctions Act (CAATSA), a bill that he called "seriously flawed" in a statement about CAATSA issued at the same time he signed the bill.

As discussed in our prior blog posts here, here, and here, CAATSA calls for the imposition of certain additional sanctions targeting Iran, Russia, and North Korea. The timing and implementation of many of these sanctions remains uncertain. While some provisions in CAATSA require the President to implement the sanctions within a prescribed period of time (e.g., the modifications to Directives 1 and 2 under US Sectoral Sanctions will take effect 60 days after the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) modifies them), others do not and will require implementing action by the Executive Branch (e.g., designation of parties targeted under CAATSA). In addition, it remains to be seen whether or how the President will implement CAATSA’s discretionary provisions, including sanctions targeting Russian energy export pipelines.

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