New Authority To Impose Sanctions In Connection With Russian Energy Pipelines

On August 20, 2021, President Biden signed a  new Executive Order to further implement sanctions provided under the Protecting Europe's Energy Security Act ("PEESA") of 2019.  PEESA, which was enacted earlier this year, requires the State Department to issue a periodic report naming parties involved in the construction certain Russian energy export pipelines.  Last week's E.O. authorizes sanctions on any person named in that report, subject to certain exceptions, and directs the Treasury and the State Departments to issue rules to implement those sanctions.

As background,  PEESA directs the State Department, in consultation with the Treasury Department, to identify (1) vessels engaged in certain pipe-laying activities for the Nord Stream 2 and Turkstream pipeline projects, as well as any successor projects; and, (2) foreign persons that knowingly facilitated those projects who: