For Russia, Sanctions Are Coming

Morrison & Foerster LLP

Back in February, we told you about the Defending American Security from Kremlin Aggression Act, or “DASKA,” a bipartisan effort to impose new sanctions on Russia. Interest in action against the Kremlin has only increased following the Mueller Report’s release, with Congress now considering no fewer than five Russia-focused sanctions bills. The latest of the bunch explicitly threatens the Nord Stream 2 gas pipeline project, sanctions against which U.S. Energy Secretary Rick Perry says are inevitable:

“The opposition to Nord Stream 2 is still very much alive and well in the United States,” Perry said during a visit to Kiev on May 21, 2019, according to media reports. “The United States Senate is going to pass a bill, the House is going to approve it, and it’s going to go to the President, and he’s going to sign it, that is going to put sanctions on Nord Stream 2.”

That threat in particular is sending shockwaves across Europe, as German Chancellor Angela Merkel has publicly supported Nord Stream 2 as vital to Germany’s energy security. This is not the first time Nord Stream 2 has been in congressional crosshairs; in 2017, Congress passed the Countering America’s Adversaries Through Sanctions Act (CAATSA), which included a provision that allows the Administration to target certain high-value investments or sales for the construction of Russian energy export pipelines. That authority, however, is discretionary, and its implementing agency, the U.S. State Department, subsequently issued guidanceindicating that only projects initiated after CAATSA’s enactment would be subject to sanctions, thereby effectively excluding Nord Stream 2 and easing tensions with Germany and others. The latest bill, which calls for mandatory sanctions, leaves no room for similar diplomatic maneuvering.

With so many bills circulating and so much at stake for business interests around the world, your MoFo National Security team prepared a brief primer on each bill, with the caveats that additional bills and amendments are likely forthcoming and the legislative timeline remains unclear. Note that many of the bills contain overlapping features that would require sanctions against Russian energy projects, oligarchs, and newly issued sovereign debt – an indication that measures related to these sanctions targets will likely make it into whatever ultimately becomes law.

The Protecting Europe’s Energy Security Act of 2019 (PEESA) – filed on May 14, 2019 by Senators Cruz, Shaheen, Barrasso, and Cotton – would require the Secretary of State to issue a report within 60 days, and every 90 days thereafter, on (1) vessels that engaged in pipe-laying at depths of 100 feet or more below sea level for the construction of Russian energy export pipelines; and (2) foreign persons that have sold, leased, provided, or facilitated the provision of those vessels for the construction of such pipelines. As a result of being identified in any of the reports, the following sanctions would result:

  • The assets subject to U.S. jurisdiction of any foreign persons (individuals or entities) identified in (2) above would be required to be blocked (or frozen);
  • The corporate officers and principal shareholders of any company owning a vessel identified in (1) above, as well as any foreign persons identified in (2) above, would be denied visas and prohibited from entering the United States; and
  • A menu of possible sanctions, including asset freezes, could be imposed on any foreign persons that provided underwriting services or insurance or reinsurance for a vessel identified in (1) above, as well as on the corporate officers of any such companies.

The bill would provide the Administration with authority to waive the application of sanctions based on national security considerations, but in the current political climate, such a waiver would be extremely difficult for the Administration to issue. The bill also calls for a report within six months and annually thereafter (1) listing all entities, including financial institutions, that directly or indirectly provided goods, services, or technology for the construction or repair of the Nord Stream 2 pipeline and (2) assessing whether such entities had knowingly engaged in a “significant transaction” with a sanctioned Russian party. Any positive assessment presumably would force the Administration into imposing sanctions against any such entity, given that CAATSA requires that such significant transactions result in mandatory secondary sanctions.

As with CAATSA, much of the bill is phrased neutrally in terms of “Russian energy export pipelines,” but the sponsors are clearly focused on Nord Stream 2. “Nord Stream 2 threatens Europe’s energy security,” Senator Cruz noted upon the bill’s filing. “The United States simply cannot allow Russia to dominate Europe’s energy future.”

The Defending Elections from Threats by Establishing Redlines Act of 2019 (DETER) – introduced April 8, 2019, by Senators Van Hollen and Rubio – would require (1) determinations and reports to Congress by the Director of National Intelligence (DNI) within 60 days of a U.S. election on whether, with a high level of confidence, a foreign government or agent of a foreign government knowingly interfered in the election; (2) annual reports to Congress providing information on Russian oligarchs, senior political figures, and parastatal entities; and (3) biannual reports to Congress on the wealth, sources of wealth, and use of wealth of such persons, including Russian President Putin. As sanctions watchers recall, it was a similar provision of CAATSA that resulted in the extraordinary sanctions against Russian oligarchs in April 2018 whose effects were (and continue to be) felt around the world.

If the DNI determines under (1), above, that Russia or a Russian agent interfered in an election, the United States must, within 30 days of that determination, impose the following sanctions:

  • Blocking and/or correspondent account sanctions on at least two of the following major Russian banks: (1) Sberbank; (2) VTB Bank; (3) Gazprombank; (4) Vnesheconombank (VEB); and (5) Rosselkhozbank;
  • Prohibitions on new investments in the Russian energy sector, including blocking sanctions on any foreign person (individual or entity) that makes a new investment in the Russian energy sector or a Russian energy company;
  • Blocking and visa sanctions on Russian senior political figures and oligarchs determined by the DNI to have directly or indirectly contributed to the election interference;
  • Blocking sanctions on entities that are part of, or operate on behalf of, the Russian defense or intelligence sectors; and
  • Prohibitions on all transactions in (1) sovereign debt of the Russian government issued after the enactment of DETER and (2) debt of any entity owned or controlled by Russia issued after the enactment.

The bill would provide the President with limited power to waive or suspend sanctions. The President may waive sanctions (except with respect to senior political figures and oligarchs) by certifying that (1) the waiver is in the vital national security interest of the United States; and (2) failing to use the waiver will cause significant adverse harm to the vital national security interests of the United States. The President may suspend sanctions if the DNI certifies that the Russian government has not engaged in interference in U.S. elections for at least one Federal election cycle. Should Russia, after any suspension of sanctions, fail to show there is improved government oversight of and prosecutions relating to interference in U.S. elections and credibly demonstrate a significant change in behavior and credibly commit to not engaging in such interference in the future, the President must reimpose sanctions.

The Defending American Security from Kremlin Aggression Act (DASKA) – introduced on February 13, 2019 by Senators Graham, Menendez, Gardner, Cardin, and Shaheen – would, as we previously reported, confront the Kremlin on a range of issues, including Russia’s continued interference in democratic processes in the United States and abroad, malign influence in Syria, continued aggression toward Ukraine, and support of criminal organizations and other malicious actors in cyberspace. The bill runs for 119 pages, contains provisions dealing with all sorts of Russian (and non-Russian) policy measures, and would require:

  • Sanctions on any person that knowingly makes a new large investment in a liquefied natural gas (LNG) export facility outside Russia or any energy project outside Russia “supported by” a Russian parastatal entity or an entity owned or controlled by the Russian Government;
  • Sanctions against the sale, lease, or provision of high-value goods, services, technology, financing, or other support, including infrastructure repair or modernization, which significantly contributes to the Russian Government’s development and production of crude oil resources in Russia (but would not apply to efforts to maintain projects ongoing on the date of DASKA’s enactment);
  • Sanctions on Russian oligarchs linked to President Putin who facilitate bad acts on his behalf;
  • Prohibitions on U.S. persons from dealing in new Russian sovereign debt – including bonds issued by, and foreign exchange swap agreements with, the Russian Central Bank, National Wealth Fund, or Federal Treasury – exceeding 14 days’ maturity;
  • Sanctions on Russian financial institutions that provide financial or other support for Russian government interference in democratic processes outside Russia; and
  • Mandatory quarterly determinations by the Secretary of State on whether the Russian Government was interfering with freedom of navigation anywhere in the world, and if so, would require sanctions against all entities operating in the Russian shipbuilding sector.

DASKA also would require the Secretary of State to determine, within three months, whether Russia is a state sponsor of terrorism, which – in the event of an affirmative determination – would result in additional sanctions and export restrictions. It also would incorporate the International Cybercrime Prevention Act (ICPA), which has been introduced in Congress in various forms since 2015 and seeks to raise the costs on malicious cyber activity. The bill would create additional authorities to seize botnets and prohibit cyber criminals from selling access to botnets to carry out cyber attacks – seeking to build on the U.S. government’s successful disruption of the Coreflood botnet in 2011 and the Gameover Zeus botnet in 2014, both of which emanated from Russia.

The bill also contains long-discussed beneficial ownership provisions to require domestic title insurance companies to obtain, maintain, and report information on beneficial owners of entities that purchase high-value residential real estate in the United States. This requirement is similar to FinCEN’s temporary geographic targeting orders that require companies to collect and report beneficial ownership and other ownership information for all cash transactions exceeding $300,000 by legal entities for real estate located in specific metropolitan areas in Texas, Florida, New York, California, Hawaii, Nevada, Washington, Massachusetts, and Illinois.

A Bill To Respond to and Deter Russian Attacks on the Integrity of United States Elections – discussed at a House hearing on May 15, 2019 but not yet introduced – would require:

  • Within 90 days of enactment, blocking sanctions against any energy project located outside Russia, where the Russian Government or a Russian parastatal invests more than $5 million after a 90-day period after enactment;
  • Within 90 of enactment, blocking sanctions against any Russian financial institution or Russian person that assisted with election interference by the Russian Government in the 2016 or 2018 U.S. elections;
  • Within 60 days of enactment, prohibitions on U.S. persons from transacting with, financing, or otherwise dealing in Russian sovereign debt issued at least 90 days after enactment;
  • Within 90 days of enactment, requirements on U.S. persons to disclose equity interests in large Russian banks (Vnesheconombank (VEB), Sberbank, VTB Bank, Gazprombank, Rosselkhozbank, and Promsyvabank)

For future elections, the DNI would be required, within 60 days of a U.S. election, to report to Congress with a high level of confidence whether the Russian government or a Russian agent knowingly interfered in an election. If so, the following sanctions would be required:

  • New sanctions on one or more of the six Russian financial institutions listed above or on the Russian Direct Investment Fund;
  • Prohibitions on new U.S. investments in the energy sector of Russia or Russian energy companies;
  • Sanctions on any foreign person that makes a new investment in Russia’s energy sector or energy companies owned by Russia;
  • Blocking sanctions on all defense firms owned by Russia, including Rostec.

As noted above, these bills are the latest word in the ongoing conversation in Congress about how to deal with Russia and an Administration oft-criticized for not taking a harder line against the Kremlin. We in MoFo’s National Security Practice Group will continue to keep you informed as the dialogue progresses.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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