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ARTICLE · 27 JULY 2020

Updated Guidance For Section 232 Of CAATSA Published

Cleary Gottlieb Steen & Hamilton LLP
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Yesterday, updated guidance from the U.S. Department of State relating to Section 232 of the Countering America's Adversaries Through Sanctions Act of 2017 ("CAATSA") was published in...

GlobalInternational Law

Yesterday, updated guidance from the U.S. Department of State relating to Section 232 of the Countering America's Adversaries Through Sanctions Act of 2017 ("CAATSA") was published in the Federal Register.1 The updated guidance, which became effective on July 15, 2020, expands the potential applicability of secondary sanctions pursuant to Section 232 with respect to Nord Stream 2 and the second line of TurkStream. Any work on or financial involvement in NordStream 2 or the second line of TurkStream will now be sanctionable, even if undertaken pursuant to an existing contract. This could affect, among other things, lending and other financing to companies (including European companies) with any connection to either project.

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