Executive Summary
On March 2, 2021, the Biden Administration, in a coordinated announcement by the U.S. Departments of Treasury, State, and Commerce, tightened export restrictions against Russia and imposed sanctions and other measures on certain Russian entities and individuals allegedly involved in the poisoning and subsequent imprisonment of Alexei Navalny, a Russian opposition leader and anti-corruption crusader who recently returned to Russia after being treated for Novichok poisoning in Germany. Earlier in the day, the EU had announced the addition of two of the same individuals identified by the U.S. to its sanctions list, which marked the first time the EU had implemented sanctions under the Human Rights Sanctions Regime which it introduced in early December 2020. The EU had already sanctioned six other individuals and one entity in October 2020 (many of whom were listed in the U.S. action on March 2) over the poisoning using the framework of the EU’s restrictive measure
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2021 will present opportunities for the advanced nuclear and space exploration sectors, but companies should be cognizant of complex compliance standards.
TAKEAWAYS
The prior Administration’s January 12, 2021 Executive Order (EO) promoting advanced reactors and the use of nuclear technology for defense purposes and space exploration seeks to provide direction and initiative to other, ongoing federal efforts in these sectors. Given the bipartisan support for advanced nuclear technology and the inclusion of nuclear energy as a key solution in the Biden plan for a clean energy revolution, it is likely that the Biden Administration will continue advancing the initiatives set out in the EO.
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The U.S. Department of State (“State Department”) announced the imposition of sanctions on Turkey’s Presidency of Defense Industries (“SSB”) pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”). The U.S. is sanctioning SSB over its procurement of the S-400 surface-to-air missile system from Russia’s Rosoboronexport (“ROE”). SSB is Turkey’s primary defense procurement entity and ROE is Russia’s main exporter of arms. As a result of Turkey’s actions, the U.S. is imposing full blocking sanctions on four SSB officials along with certain non-blocking CAATSA sanctions on the SSB entity.
December 18, 2020
On December 14, 2020, the United States imposed sanctions on the Republic of Turkey’s Presidency of Defense Industries (“SSB”), the country’s defense procurement agency, and four senior officials at the agency, for knowingly engaging in a “significant transaction” with Rosoboronexport (“ROE”), Russia’s main arms export entity, in procuring the S-400 surface-to-air missile system. These measures were a long-time coming under Section 231 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) of 2017, the President has been
required to impose sanctions on any person determined to have knowingly “engage[d] in a significant transaction with a person that is part of, or operates for or on behalf of, the defense or intelligence sectors of the Government of the Russian Federation.” This includes ROE, and Turkey’s multi-billion dollar S-400 transaction with ROE has been public knowledge for at least three years. Indeed, in