U.S. State Department publishes new CAATSA Section 232 Public Guidance

The U.S. Department of State has updated the Countering America’s Adversaries Through Sanctions Act (CAATSA) Section 232 public guide. The purpose of the public guidance update is to “address certain growing threats to U.S. national security and foreign policy interests . . . particularly with respect to Nord Stream 2 and the second line of TurkStream.” The State Department has deleted portions of the public guidance that were in effect prior to 15th July 2020. These deleted portions 1) had limited Section 232 to Russian energy export pipeline projects for which a contract was signed on or after 2nd August 2017 and 2) had stated that investments and loans made prior to 2nd August 2017 would not be subject to Section 232. For further information please see the updated guidance from the U.S. Department of State.