OFAC issued a new FAQ concerning implementation of
sanctions related to two Russia-related pipeline projects under the
National Defense Authorization Act
("NDAA") for Fiscal Year 2020.
New FAQ #815 concerns the implementation of sanctions under
Section 7503(d) ("Wind-down Period") provisions of the
NDAA. The sanctions became effective on December 20. The FAQ states
that "involved parties that have knowingly sold, leased, or
provided vessels that are engaged in pipe laying at depths of 100
feet or more below sea level for the construction of Nord Stream 2
or Turkstream [pipelines] must ensure that such vessels immediately
cease construction-related activity." The FAQ adds that
"good-faith wind-down exceptions may be made for the safety of
the pipeline or safety and care of the crew aboard the vessel, the
protection of human life, or maintenance to avoid any environmental
or other significant damage, as further described in Section
7503(e)["Exceptions"] of the NDAA."
