National Defense Authorization Act – Implications For U.S. Sanctions Programs

In a closely followed and much anticipated action, President Biden signed the National Defense Authorization Act for Fiscal Year 2022 (NDAA) on December 27, 2021 - following its approval by the U.S. Senate and House of Representatives earlier in December. The final NDAA, viewed as a "must-pass" piece of legislation because it provides annual funding for the U.S. military, represents a compromise measure incorporating provisions of a different version previously passed by the House together with Senate amendments.

The NDAA impacts a wide range of national security concerns and may have important long-term implications for multiple sanctions programs, as we discuss below.  However, its overall impact on U.S. sanctions is relatively minor - especially when compared to all of the proposed amendments touching on U.S. sanctions that could have made their way into the final bill. Indeed, the NDAA's passage through the Senate was forestalled by a number of Senators trying