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CAATSA Overview

Congress enacted the “Countering America’s Adversaries Through Sanctions Act” (CAATSA) on August 2, 2017 in response to Russia’s continuing occupation of the Crimea region of Ukraine and cyber-interference in the 2018 United States Presidential elections. We previously covered CAATSA in blog posts here and here. CAATSA was notable because it passed the House of Representatives with a 419-3 approval margin and passed the Senate with a 98-2 approval margin. Among other things, CAATSA required President Donald Trump to take certain actions on the 180-day anniversary of CAATSA’s adoption, which included (but were not limited to): (i) imposing sanctions (commonly referred to as the “CAATSA Section 231 sanctions”) against persons engaged in “significant transactions” with Russia’s defense or intelligence sectors; and (ii) preparing and submitting a report (commonly referred to as the “CAATSA Section 241 report”) to various congressional committees identifying senior political figures and oligarchs within Russia. January 29, 2018 marked CAATSA’s 180-day anniversary and, as a result, it sparked a flurry of activity related to the CAATSA Section 231 sanctions and the CAATSA Section 241 report.

Today, President Trump officially signed H.R. 3364, the “Countering America’s Adversaries Through Sanctions Act” (CAATSA) into law. CAATSA originated as a bill which was focused on only Iran. However, partially in response to Russian cyber-interference with the 2016 election, the Senate expanded CAATSA to impose additional sanctions against Russia and also codify into law various sanctions imposed by the Obama Administration in the form of Executive Orders. The House of Representatives then approved these additions and added further sanctions against North Korea. Eventually, the House and Senate approved the final version of CAATSA by a margin of 419-3 and 98-2, respectively. For additional detail on CAATSA’s legislative history, please see our previous alerts here, here and here.

Yesterday, July 25th, the U.S. House of Representatives passed the “Countering America’s Adversaries Through Sanctions Act” by a vote of 419-3. The bill originated as an act in the Senate which was focused on Iran. In response to Russian meddling in the U.S. election, the Senate expanded that bill to include additional sanctions against Russia, codify various Russia-Ukraine sanctions promulgated by the Obama Administration into law and add procedural provisions to delay or prevent any efforts by the Trump Administration to relax those codified Obama Administration sanctions. The Senate passed their revised version of this legislation last month by a vote of 98-2. For more information on the Senate’s earlier approval, please see our post on June 16th.