Trump Administration Broadens Sanctions On Russian Pipeline Projects (Again)

On October 20, 2020, the U.S. Department of State ("State") broadened, yet again, the scope of sanctions applicable to Russian energy export pipeline projects, most notably the Nord Stream 2 pipeline, a nearly finished Russian-backed natural-gas pipeline that has been a hot-button geopolitical issue in recent years. Specifically, State published guidance that expands existing sanctions imposed by the Protecting Europe's Energy Security Act of 2019 ("PEESA"), which targeted the underwater vessels used for construction of Russian energy export pipelines such as the Nord Stream 2 and TurkStream pipeline projects, indicating that sanctions would now apply to companies providing services, facilities, or funding for "upgrades or installation of equipment" for vessels working on the projects. State's action comes only a few months after a similar announcement in July 2020 removed a grandfather clause that the Trump administration created in 2017 that had exempted the Nord