Since the U.S. government determined that Russia interfered in the 2016 election, movement around Russia sanctions policy has been vigorous, if not unidirectional. Twice in 2016, the United States implemented sanctions against Russia: In September, dozens of individuals and entities were sanctioned with regard to Russian operations in Crimea. In December, President Obama expelled 35 Russian intelligence agents from the U.S. and imposed sanctions on two major intelligence services, as a response to those interferences from Russia. In 2017, concerned that the new administration might roll back certain sanctions on Russia, Congress overwhelmingly passed the Countering America’s Adversaries Through Sanctions Act, codifying and adding to sanctions on Russia already in place.

In January, we anticipated two more moves mandated under CAATSA: 1) the publication of a list of senior political figures and oligarchs in the Russian Federation and 2) sanctions against entities and individuals that had conducted significant transactions with the defense and intelligence sectors in Russia. It appears that one was a feint and the other a flop.

Originally published in Law360 on January 9, 2018.