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."