Under Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), the Trump administration was due to issue secondary sanctions on non-U.S. persons that conduct significant transactions with Russia’s defense and intelligence sectors. The Trump administration declined to issue those new sanctions, claiming that CAATSA was serving as an effective deterrent – discouraging non-U.S. entities from doing business with the Russian defense and intelligence sectors – and that no new sanctions were needed at this time.

Non-U.S. companies should remain on notice that the U.S. government retains the ability to sanction non-U.S. firms for dealings with the Russian military and intelligence sectors, should the administration choose to exercise that authority in the future.