The United States has taken significant steps toward fully implementing the sanctions imposed on Russia pursuant to the Countering America’s Adversaries Through Sanctions Act of 2017, which codifies and strengthens certain existing sanctions on Russia.

Although the Act was enacted in August 2017, the full scope of the sanctions it imposes on Russia recently have come into greater focus with issuance of formal guidance from the U.S. Department of the Treasury’s Office of Foreign Assets Control and the U.S. Department of State. U.S. and non-U.S. companies and financial institutions should continue to review their business activities involving Russia to ensure ongoing compliance with applicable U.S. sanctions.