On 27 October, the U.S. Department of State published guidance with respect to Russia’s Defense and Intelligence sectors under section 231 of the Countering America’s Adversaries The Sanctions Act (CAATSA). Section 231 requires the imposition of certain sanctions on persons determined to have knowingly engaged in a “significant transaction,” on or after 2 August, the date that CAATSA was enacted, with a person that is part of or operating for or on behalf of the defense or intelligence sectors of the Russian government. The guidance was published after the statutory deadline and after congressional and media criticism over the delay.