• Introduction
• U.S. Sanctions on Russia: A Key Policy Tool
• Russia Sanctions and the Trump18, 2022 In early 2022, Congress, the Biden Administration, and other stakeholders are considering the prospect of new sanctions on Russia. In response to a Russian military buildup near and in Cory Welt, Coordinator Ukraine, the United States and European allies have said they would impose additional sanctions Specialist in Russian and in the event of further Russian aggression against Ukraine. Such sanctions could include greater European Affairs restrictions on transactions with Russian financial institutions and U.S. technology exports, as well as the suspension of Russia’s pending Nord Stream 2 natural gas pipeline project. Further additional sanctions, including on Russia’s energy sector and secondary market transactions in Kristin Archick Specialist in European Russian sovereign debt, also may be under consideration. Affairs Sanctions are a central element of U.S. policy to counter and deter malign Russian activities. The United States maintains sanctions on Russia mainly in response to Russia’s invasion of Ukraine Rebecca M. Nelson starting in 2014 Administration
• How Effective Are Sanctions on Russia?
• About the Report
• Use of Economic Sanctions to Further Foreign Policy and National Security Objectives
• Role of the President
• Role of Congress
• Sanctions Implementation
• U.S. Sanctions on Russia
• Sergei Magnitsky Act and the Global Magnitsky Act
• Sanctions Related to Russia's Invasion of Ukraine
• Specially Designated Nationals
• Sectoral Sanctions Identifications
• Ukraine-Related Legislation
• Election Interference and Other Malicious Cyber-Enabled Activities
• Related Actions
• Countering Russian Influence in Europe and Eurasia Act of 2017
• Issues Related to CRIEEA Implementation
• Use of a Chemical Weapon
• Other Sanctions Programs
• Weapons Proliferation
• North Korea Sanctions Violations
• Syria-Related Sanctions
• Venezuela-Related Sanctions
• Energy Export Pipelines
• Transnational Crime
• Terrorism
• Restrictions on U.S. Government Funding
• Russian Countersanctions
• U.S. and EU Coordination on Sanctions
• U.S. and EU Cooperation on Ukraine-Related Sanctions
• U.S. and EU Ukraine-Related Sanctions Compared
• Sanctions Targeting Individuals and Entities
• Sectoral Sanctions
• Developments Since 2017
• Potential New EU Sanctions on Russia
• Economic Impact of Sanctions on Russia
• Russian Economy Since 2014
• Estimates of the Broad Economic Impact
• Factors Influencing the Broad Economic Impact
• Impact on Russian Firms and Sectors
• Factors Influencing the Impact on Firms and Sectors
• Outlook

Sanctions are a central element of U.S. policy to counter and deter malign Russian behavior. The United States has imposed sanctions on Russia mainly in response to Russia's 2014 invasion of Ukraine, to reverse and deter further Russian aggression in Ukraine, and to deter Russian , to reverse and deter further Russian aggression in Ukraine, and to deter Russian Specialist in International aggression against other countries. The United States also has imposedmaintains sanctions on Russia in Trade and Finance response to (and to deter) election interference and other malicious cyber-enabled activities, human rights abuses, the use of a chemical weapon, weapons proliferation, illicit trade with North Korea, and support to Syria and Venezuela. Mostmalicious cyber-enabled activities and influence operations (including election interference), the use of a chemical weapon, human rights abuses, the use of energy Dianne E. Rennack exports as a coercive or political tool, weapons proliferation, illicit trade with North Korea, and Specialist in Foreign Policy support to the governments of Syria and Venezuela. Many Members of Congress support a robust Legislation Members of Congress support a robust use of sanctions amid concerns about Russia'’s international behavior and geostrategic intentions.

Sanctions related to Russia'’s invasion of Ukraine are based mainly on four executive orders (EOs (E.O.s) that President Obama issued in 2014. That year, Congress also passed and President Obama signed into law two acts establishing sanctions in response to Russia's invasion of Ukraine: the Legislation establishing sanctions specifically in response to Russian actions includes the following:  Sergei Magnitsky Rule of Law Accountability Act of 2012 (P.L. 112-208, Title IV; 22 U.S.C. 5811 note)  Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014, as amended (SSIDES; P.L. 113-95/H.R. 4152) and the ; 22 U.S.C. 8901 et seq.)  Ukraine Freedom Support Act of 2014, as amended (UFSA; P.L. 113-272/H.R. 5859).

In 2017, Congress passed and President Trump signed into law the P.L. 113-272; 22 U.S.C. 8921 et seq.)  Countering Russian Influence in Europe and Eurasia Act of 2017, as amended (CRIEEA; P.L. 115-44/H.R. 3364, , Countering America'’s Adversaries Through Sanctions Act [CAATSA], Title II). This legislation codified Ukraine-related and cyber-related EOs, strengthened sanctions authorities initiated in Ukraine-related EOs and legislation, and identified several new targets for sanctions. It also established congressional review of any action the President takes to ease or lift a variety of sanctions.

In terms of economic impact, studies suggest that sanctions have had a negative but relatively modest impact on Russia's growth. Changes in world oil prices have had a much ; 22 U.S.C. 9501 et seq.)  Protecting Europe’s Energy Security Act of 2019, as amended (PEESA; P.L. 116-92, Title LXXV; 22 U.S.C. 9526 note) In imposing sanctions on Russia, the United States has coordinated many of its actions with the European Union (EU) and others. As the invasion of Ukraine progressed in 2014, the Obama Administration considered EU support for sanctions to be crucial, as the EU had more extensive trade and investment ties with Russia than the United States. Many policymakers and observers view ongoing U.S.-EU cooperation in imposing sanctions as a tangible indication of U.S.-European solidarity, frustrating Russian efforts to drive a wedge between transatlantic partners. In terms of economic impact, studies suggest sanctions have had a negative but relatively modest impact on Russia’s growth. Changes in world oil prices and the Coronavirus Disease 2019 (COVID-19) pandemic appear to have had a greater impact than sanctions greater impact on the Russian economy. After oil prices rose in 2016, Russia'’s economy began to strengthen even as sanctions remained in place and, in some instances, were tightened. The Obama Administration and the EU designed sanctions related to Russia'’s invasion of Ukraine, in part, to impose longer-term pressures on Russia'’s economy while minimizing collateral damage to the Russian people and to the economic interests of the countries imposing sanctions. Congressional Research Service link to page 5 link to page 5 link to page 6 link to page 7 link to page 7 link to page 9 link to page 9 link to page 10 link to page 10 link to page 11 link to page 11 link to page 13 link to page 14 link to page 16 link to page 16 link to page 18 link to page 23 link to page 23 link to page 24 link to page 25 link to page 27 link to page 27 link to page 28 link to page 29 link to page 31 link to page 32 link to page 32 link to page 34 link to page 35 link to page 36 link to page 36 link to page 37 link to page 37 link to page 38 link to page 39 link to page 39 link to page 42 link to page 43 link to page 44 link to page 44 link to page 45 link to page 47 link to page 48 U.S. Sanctions on Russia Contents Introduction ..................................................................................................................................... 1 U.S. Sanctions on Russia: A Key Policy Tool ........................................................................... 1 How Effective Are Sanctions on Russia? .................................................................................. 2 About the Report ....................................................................................................................... 3 Use of Economic Sanctions to Further Foreign Policy and National Security Objectives .............. 3 Role of the President ................................................................................................................. 5 Role of Congress ....................................................................................................................... 5 Sanctions Implementation ......................................................................................................... 6 U.S. Sanctions on Russia ................................................................................................................. 6 Sanctions Related to Russia’s Invasion of Ukraine................................................................... 7 Specially Designated Nationals .......................................................................................... 7 Sectoral Sanctions Identifications ....................................................................................... 9 Ukraine-Related Legislation ............................................................................................. 10 Election Interference and Other Malicious Cyber-Enabled or Intelligence Activities ............ 12 Sanctions Authorities ........................................................................................................ 12 Related Actions ................................................................................................................. 14 Use of a Chemical Weapon ..................................................................................................... 19 CBW Act Sanctions .......................................................................................................... 19 Poisoning of Sergei Skripal............................................................................................... 20 Poisoning of Alexei Navalny ............................................................................................ 21 Human Rights Abuses and Corruption .................................................................................... 23 Sanctions Authorities ........................................................................................................ 23 Related Actions ................................................................................................................. 24 Section 241 “Oligarch” List and Related Sanctions ......................................................... 25 Nord Stream 2: Energy Exports as a Coercive or Political Tool ............................................. 27 Other Sanctions Programs ....................................................................................................... 28 Weapons Proliferation ....................................................................................................... 28 North Korea Sanctions Violations ..................................................................................... 30 Syria-Related Sanctions .................................................................................................... 31 Venezuela-Related Sanctions ............................................................................................ 32 Transnational Crime .......................................................................................................... 32 Terrorism ........................................................................................................................... 33 Restrictions on U.S. Government Funding ............................................................................. 33 Russian Countersanctions .............................................................................................................. 34 U.S. and EU Coordination on Sanctions ....................................................................................... 35 Comparing U.S. and EU Ukraine-Related Sanctions .............................................................. 35 EU Concerns About U.S. Sanctions After 2017 ...................................................................... 38 Other EU Sanctions in Response to Russian Activities .......................................................... 39 Economic Impact of Sanctions on Russia ..................................................................................... 40 Impact on Russia’s Economy Broadly .................................................................................... 40 Impact on Russian Firms ......................................................................................................... 41 Impact on Russian Government Finances ............................................................................... 43 Outlook .......................................................................................................................................... 44 Congressional Research Service link to page 44 link to page 14 link to page 51 link to page 56 link to page 60 link to page 61 link to page 50 link to page 51 link to page 58 link to page 60 link to page 61 link to page 62 U.S. Sanctions on Russia Figures Figure 1. Economic Growth in Russia, 1994-2021 ....................................................................... 40 Tables Table 1. U.S. Sanctions Related to Russia’s Invasion of Ukraine ................................................. 10 Table B-1. U.S. Sanctions on Russia for Which Designations Have Been Made ......................... 47 Table B-2. U.S. Sanctions on Russia for Which Designations Have Yet to Be Made ................... 52 Table D-1. U.S. and EU Sectoral Sanctions .................................................................................. 56 Table E-1. Russia’s Largest Firms and U.S. Sanctions ................................................................. 57 Appendixes Appendix A. Legislative Abbreviations and Short Titles .............................................................. 46 Appendix B. U.S. Sanctions on Russia ......................................................................................... 47 Appendix C. Sanctions in Selected Russia-Related Legislation ................................................... 54 Appendix D. U.S. and EU Sectoral Sanctions ............................................................................... 56 Appendix E. Russian Firms and U.S. Sanctions ........................................................................... 57 Contacts Author Information ........................................................................................................................ 58 Congressional Research Service U.S. Sanctions on Russia Introduction minimizing collateral damage to the Russian people and to the economic interests of the countries imposing sanctions.

U.S. Sanctions on Russia: A Key Policy Tool

U.S. Sanctions on Russia: A Key Policy Tool Sanctions are a central element of U.S. policy to counter and deter malign Russian behavioractivities. The United States has imposedmaintains sanctions on Russia mainly in response to Russia'’s 2014 invasion of Ukraine, to reverse and deter further Russian aggression in Ukraine, and to deter Russian aggression against other countries. The United States also has imposedmaintains sanctions on Russia in response to (and to deter) election interference and malicious cyber-enabled activities, human rights abuses, the use of a chemical weapon and influence operations (including election interference), the use of a chemical weapon, human rights abuses, the use of energy exports as a coercive or political tool, weapons proliferation, illicit trade with North Korea, and support to the governments of Syria and Venezuela. MostMany Members of Congress support a robust use of sanctions amid concerns about Russia'’s international behavior and geostrategic intentions.

Sanctions related to Russia'’s invasion of Ukraine are based mainly on national emergency authorities granted the office of the President in the National Emergencies Act (NEA; P.L. 94-412412; 50 U.S.C. 16211601 et seq.) and International Emergency Economic Powers Act (IEEPA; P.L. 95-223; 50 U.S.C. 1701 et seq.) and exercised by President Barack Obama in 2014 in a series of executive orders (EOsE.O.s 13660, 13661, 13662, 13685). The Obama and Trump , Trump, and Biden Administrations have used these EOsE.O.s to impose sanctions on more than 680 Russian individuals, entities, vessels, and aircraft.

hundreds of individuals and entities (as well as on vessels and aircraft). The executive branch also has used a variety of EOsE.O.s and legislation to impose sanctions on RussianRussia and related individuals and entities in response to a number of other concerns. numerous other activities of concern. Legislation that established sanctions specifically on Russian individuals and entitiesin response to Russian actions includes the following:

•  Sergei Magnitsky Rule of Law Accountability Act of 2012 (P.L. 112-208, Title IV; 22 U.S.C. 5811 note).
•  Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014, as amended (SSIDES; P.L. 113-95; 22 U.S.C. 8901 et seq.).
•  Ukraine Freedom Support Act of 2014, as amended (UFSA; P.L. 113-272; 22 U.S.C. 8921 et seq.).
•  Countering Russian Influence in Europe and Eurasia Act of 2017, as amended (CRIEEA; P.L. 115-44, Countering America'’s Adversaries Through Sanctions Act [CAATSA], Title II; 22 U.S.C. 9501 et seq.).

Russia Sanctions and the Trump Administration

The United States imposed sanctions related to Russia's invasion of Ukraine in coordination  Protecting Europe’s Energy Security Act of 2019, as amended (PEESA; P.L. 116- 92, Title LXXV; 22 U.S.C. 9526 note) In imposing sanctions on Russia, the United States has coordinated many of its actions with the European Union (EU), the United Kingdom (UK), and others. As the invasion of Ukraine progressed in 2014, the Obama Administration argued thatconsidered EU support for sanctions wasto be crucial, as the EU hashad more extensive trade and investment ties with Russia than does the United States. Many viewpolicymakers and observers view ongoing U.S.-EU cooperation in imposing sanctions as a tangible indication of U.S.-European solidarity, frustrating Russian efforts to drive a wedge between transatlantic partners. Congressional Research Service 1 link to page 45 link to page 6 U.S. Sanctions on Russia How Effective Are Sanctions on Russia? Many observers have debated the degree to which sanctions and the possibility of future sanctions promote change in Russia’s behavior. Russia has deepened its hold over Ukraine’s occupied Crimea region and separatist regions in eastern Ukraine. Russiabetween transatlantic partners. Since 2017, however, the efforts of Congress and the Trump Administration to tighten U.S. sanctions have been more unilateral, prompting some concern in the EU about U.S. commitment to sanctions coordination and U.S.-EU cooperation on Russia and Ukraine more broadly.

How Effective Are Sanctions on Russia?

Many observers have debated the degree to which sanctions promote change in Russia's behavior. With respect to Ukraine, Russia has not reversed its occupation and annexation of Crimea, nor has it stopped sustaining separatist regimes in eastern Ukraine. It also has extended military operations to nearby waters, interfering with commercialmaritime traffic traveling to and from ports in eastern Ukraine. In November 2018, Russian border guard vessels forcibly prevented three Ukrainian naval vessels from transiting the Kerch Strait, the waterway connecting the Black Sea to the Sea of Azov, firing on them as they sought to leave the area and imprisoning their crew members for 10 months. At the same time, Russia has signed two agreements that formally recognize Ukraine' to and from ports in eastern Ukraine, and since 2021 has engaged in a buildup of military forces near the Ukrainian border. As of mid-January 2022, however, Russia continues to nominally recognize Ukraine’s sovereignty over Russia-controlled areas in eastern Ukraine, and Russia-led separatist military operations against Ukraine have been limited to areas along the perimeter of the current conflict zone. Russia has not expanded its military aggression to other states.

With respect to other malign activities, thefurther into Ukraine or to other states. The relationship between sanctions and changes in Russianother Russian malign behavior is also difficult to determine. Sanctions in response to election interference, malicious cyber-enabled activitiesmalicious cyber, influence, and other intelligence activities, use of chemical weapons, human rights abuses, corruption, use of a chemical weaponuse of energy exports as a coercive or political tool, weapons proliferation, and support toillicit trade with North Korea, Iran, Syria,and support to Syria and Venezuela are relatively limited and highly targeted. To the extent that Russia does changechanges its behavior, other factors besides sanctions could be responsible.

For example, Russian policymakers may be willing to incur the cost of sanctions, whether on the national economy or on their own personal wealth, in furtherance of Russia' To the extent that Russian behavior does not change, it may be because Russian policymakers are willing to incur the cost of sanctions in furtherance of Russia’s foreign policy goals. Sanctions also might have the unintended effect of boosting internal support for the Russian government, whether through appeals to nationalism or through Russian elites'’ sense of self-preservation. Finally, sanctions may target individuals that have less influence on Russian policymaking than the United States assumes.

FurthermoreIn addition, the Russian government has sought to minimize the impact of sanctions on favored individuals and entities through subsidies, preferential contracts, import substitution policies, and alternative markets (see “Impact on Russian Firms,” below). In addition, the economic impact of sanctions may not be consequential enough to affect Russian policy. Studies suggest that sanctions have had a negative but relatively modest impact on Russia's growth; changes in world oil prices have had a much greater impact on the Russian economy. Most sanctions on Russia do not broadly target the Russian economy or entire sectors. Rather, they consist of broad restrictions against specific individuals and entities, as well as narrower restrictions against wider groups of Russian companies. Overall, more than four-fifths of the largest 100 firms in Russia (in 2018) are not directly subject to any U.S. or EU sanctions, including companies in a variety of sectors, such as transportation, retail, services, mining, and manufacturing.¹ Although Russia faced several economic challenges in 2014-2015, including its longest recession in almost 20 years, the 2014 collapse in global oil prices had a larger impact than sanctions.² Russia's economy strengthened in 2016 and 2017, as oil prices rose.

The relatively low impact of sanctions on the Russian economy is partially by design. The Obama Administration and the EU intended for sanctions related to Russia's invasion of Ukraine to have a limited and targeted economic impact. They’s growth and that changes in world oil prices and economic disruptions associated with the Coronavirus Disease 2019 (COVID-19) pandemic have had a greater impact than sanctions.1 Although Russia faced several economic challenges in 2014-2015, including its longest recession in almost 20 years, a collapse in global oil prices in 2014 had a larger impact than sanctions. As oil prices recovered, Russia’s economy stabilized and grew at a modest pace. Economic disruptions associated with the COVID-19 pandemic led to another contraction in 2020, followed by recovery in 2021. The modest macroeconomic effects of sanctions were largely by design. Most sanctions on Russia do not broadly target the Russian economy or entire sectors. Rather, they consist of broad restrictions against specific individuals and entities, as well as narrower restrictions on wider groups of Russian companies and certain transactions with the Russian state. The United States and the EU generally have sought to target individuals and entities responsible for offending policies and/or associated with key Russian policymakers in a way that wouldcould get Russia to change its behavior while minimizing collateral damage to the Russian people and to the economic interests of the countries imposing sanctions.³2 Moreover, some sanctions were have been intended to put only long-term pressure on the Russian economy, by denying oil companies access to Western technology to modernize their industry or develop new sources of oilfor instance by making it harder 1 International Monetary Fund (IMF), Russian Federation: Staff Report for the 2017 Article IV Consultation, July 10, 2017; and Daniel P. Ahn and Rodney D. Ludema, “The Sword and the Shield: The Economics of Targeted Sanctions,” European Economic Review, vol. 130, November 2020. 2 See, for example, U.S. Department of the Treasury, “Treasury Sanctions Russian Officials, Members of the Russian Leadership’s Inner Circle, and an Entity for Involvement in the Situation in Ukraine,” press release, March 20, 2014; and Ahn and Ludema, “The Sword and the Shield,” 2020 (see footnote 1). Congressional Research Service 2 link to page 29 link to page 29 U.S. Sanctions on Russia for Russia to modernize its oil sector with access to Western technology and capital. The full economic ramifications of thesesuch restrictions potentiallymay have yet to materialize.

There is some evidence that U.S. sanctions on Russia can have broad economic effects if they are applied to economically significant targets. HoweverAt the same time, doing so may create instability in global financial markets and opposition by U.S. allies, which generally have stronger economic relationships with Russia than the United States does. In . In April 2018, for example, the United States imposed sanctions on Rusal, a global aluminum firm, which had broad effects that rattled Russian and global financial markets. These sanctions marked the first time the United States had made a top-20 Russian firm completely off-limits, and the first time the Department of the Treasury appeared prepared to implement CRIEEA-mandated secondary sanctions. In January 2019, however, the Department of the Treasurydesignated a top Russian firm for sanctions that would affect nearly all economic activity and the first time the Treasury Department appeared ready to enforce CRIEEA-mandated secondary sanctions on persons that continued to conduct transactions with a sanctioned Russian firm. In 2019, however, the Treasury Department removed sanctions on Rusal and two related companies after Kremlin-connected billionaire Oleg Deripaska, who is subject to sanctions, agreed to relinquish his control over the three firms (for more, see "“Section 241 "Oligarch" List," below).

“Oligarch” List and Related Sanctions,” below). About the Report

This report provides a comprehensive overview of the use of sanctions in U.S. foreign policy toward Russia. It is compartmentalized, however, so that readers primarily interested in a particular issue, for example sanctions in response to Russia'’s use of a chemical weaponweapons, may find the relevant information in a subsection of the report.

The report first provides an overview of U.S. sanctions authorities and tools, particularly as they apply to Russia. It next describes various sanctions regimes that the executive branch has used to impose sanctions on Russian individuals and entitiesin response to Russian activities or that are available for this purpose, addressing authorities, tools, targets, and context. Third, the report briefly discusses countersanctions that Russia has introduced in response to U.S. and other sanctions. Fourth, it addresses the evolution of U.S. coordination with the European UnionEU on Russia sanctions policy, and similarities and differences between U.S. and EU sanctions regimes. Finally, the report assesses the economic impact of sanctions on Russia at the level of the national economy and individual firms.

Appendixes provide more detailed information regarding the use of various sanctions authorities and Russia-related targets. Use of Economic Sanctions to Further Foreign Policy and National Security Objectives

Economic sanctions provide a range of tools Congress and the President may use to seek to alter or deter the objectionable behavior of a foreign government, individual, or entity in furtherance of U.S. national security or foreign policy objectives.

Scholars have broadly defined economic sanctions as "“coercive economic measures taken against one or more countries [or individuals or entities] to force a change in policies, or at least to demonstrate a country'’s opinion about the other'’s policies.”3 Economic sanctions may include 3 Barry E. Carter, International Economic Sanctions: Improving the Haphazard U.S. Legal Regime (Cambridge: Cambridge University Press, 1988), p. 4. Also see Gary Hufbauer, Jeffrey Schott, and Kimberly Elliott et al., Economic Sanctions Reconsidered, 3rd edition (Washington, DC: Peterson Institute for International Economics, 2007); and U.S. International Trade Commission, Overview and Analysis of Current U.S. Unilateral Economic Sanctions, Investigation No. 332-391, Publication 3124, Washington, DC, August 1998. Congressional Research Service 3 link to page 9 link to page 9 U.S. Sanctions on Russia s policies."⁴ Economic sanctions may include limits on trade, such as overall restrictions or restrictions on particular exports or imports; the blocking of assets and interest in assets subject to U.S. jurisdiction; limits on access to the U.S. financial system, including limiting or prohibiting transactions involving U.S. individuals and businesses; and restrictions on private and government loans, investments, insurance, and underwriting. Sanctions also can include a denial of foreign assistance, government procurement contracts, and participation or support in international financial institutions.⁵

4 Sanctions that target third parties—those not engaged in the objectionable activity subject to sanctions but engaged with the individuals or entities that are—are popularly referred to as secondary sanctions. Secondary sanctions often are constructed to deter sanctions evasion, penalizing those that facilitate a means to avoid detection or that provide alternative access to finance.

The United States has applied a variety of sanctions in response to objectionablemalign Russian activities. Most sanctions on Russia, including most sanctions established by executive order (see "“Role of the President," ,” below), do not target the Russian state directly. Instead, they consist of designations of specific individuals, entities, vessels, and aircraft on the Specially Designated Nationals and Blocked Persons List (SDN) of the Department of the Treasury'Treasury Department’s Office of Foreign Assets Control (OFAC). Sanctions block the U.S.-based assets of thoseindividuals and entities designated as SDNs and generally prohibit U.S. individuals and entities from engaging in transactions with them.5 In addition, the Secretary of State, in consultation with the Secretary of Homeland Security and Attorney General, is tasked with denying entry into the United States of, or revoking visas granted to, designated foreign nationals.

Sanctions in response to Russia'’s invasion of Ukraine also consist of sectoral sanctions. Often, sectoral sanctions broadly apply to specific sectors of an economy. In the case of sanctions on Russia, sectoral sanctions have a narrower meaning; they apply to specific entities in Russia's ’s financial, energy, and defense sectors that OFAC has identified for inclusion on the Sectoral Sanctions Identifications (SSI) List. These sectoral sanctions prohibit U.S. individuals and entities from engaging in specific kinds of transactions related to lending, investment, and/or trade with entities on the SSI List, but they permit other transactions.

Another major category of sanctions on Russia consists of a presumption of denial to designated end users for export licenses. The Department of Commerce'’s Bureau of Industry and Security (BIS) places entities subject to export restrictions on the Entity List (Supplement No. 4 to Part 744 of the Export Administration Regulations).⁶

6 4 Not everyone agrees on what the sanctions toolbox includes. For example, some characterize export controls, limits on foreign assistance, or visa denials as foreign policy tools that are less about changing the target’s behavior than about administering U.S. foreign policy while meeting the requirements and obligations the United States assumes under treaties, international agreements, and its own public laws. See Senator Jesse Helms, “What Sanctions Epidemic? U.S. Business’ Curious Crusade,” Foreign Affairs, vol. 78, no. 1 (January/February 1999), pp. 2-8. 5 More recently, some sanctions regimes have included the designation of vessels and aircraft owned or controlled by a designated individual or entity in order to preempt sanctions evasion by means of re-registration or reflagging. 6 The Department of Commerce’s Bureau of Industry and Security (BIS) established an Entity List in 1997 to oversee U.S. compliance with international treaty and agreement obligations to control the export of materials related to weapons of mass destruction. Subsequently, the Entity List expanded to include entities engaged in activities considered contrary to U.S. national security and/or foreign policy interests. U.S. Department of Commerce, “Entity List,” at https://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/entity-list. Congressional Research Service 4 U.S. Sanctions on Russia Role of the President Role of the President

The President, for a variety of reasons related to constitutional construction and legal challenges throughout U.S. history, holds considerable authority when economic sanctions are used in U.S. foreign policy.⁷7 If Congress enacts sanctions in legislation, the President is to adhere to the provisions of the legislation but is responsible for determining the individuals and entities to be subject to sanctions.

The President also often has the authority to be the sole decisionmaker in initiating and imposing sanctions. The President does so by determining, pursuant to the International Emergency Economic Powers Act (IEEPA), that there has arisen an "“unusual and extraordinary threat, which has its source in whole or substantial part outside the United States, to the national security, foreign policy, or economy of the United States."⁸”8 The President then declares that a national emergency exists, as provided for in the National Emergencies Act (NEA), submits the declaration to Congress, and establishes a public record by publishing it in the Federal Register.⁹ 9 Under a national emergency, the President may invoke the authorities granted his office in IEEPA to investigate, regulate, or prohibit transactions in foreign exchange, use of U.S. banking instruments, the import or export of currency or securities, and transactions involving property or interests in property under U.S. jurisdiction.¹⁰

10 President Obama invoked NEA and IEEPA authorities to declare that Russia'’s 2014 invasion of Ukraine constituted a threat to the United States. On that basis, he declared the national emergency on which most sanctions related to Russia'’s invasion of Ukraine are based. In addition, President Obama and President Trump also have invoked NEA and IEEPA authorities to declare national emergencies related to cyber-enabled malicious activities and election interference.

President Biden has invoked NEA and IEEPA authorities to declare a national emergency related to a number of specified harmful foreign activities undertaken by or on behalf of the Russian government. Role of Congress Role of Congress

Congress influences which foreign policy and national security concerns the United States responds to with sanctions by enacting legislation to authorize, and in some instances require, the President to use sanctions. Congress has taken the lead in authorizing or requiring the President (or executive branch) to use sanctions in an effort to deter weapons proliferation, international terrorism, illicit narcotics trafficking, human rights abuses, regional instability, cyberattacks, corruption, and money laundering. Legislation can define what sanctions the executive branch is to apply, as well as the conditions that need to be met before these sanctions may be lifted.

One limitation on the role of Congress in establishing sanctions originates in the U.S. Constitution' 7 The Constitution divides foreign policy powers between the executive and legislative branches in a way that requires each branch to remain engaged with and supportive of, or responsive to, the interests and intentions of the other. See U.S. Congress, House Committee on Foreign Affairs, Strengthening Executive-Legislative Consultation on Foreign Policy, Congress and Foreign Policy Series (No. 8), 98th Cong., 1st sess., October 1983, pp. 9-11. 8 International Emergency Economic Powers Act (IEEPA); P.L. 95-223, §202(a); 50 U.S.C. 1701(a). For more, see CRS Report R45618, The International Emergency Economic Powers Act: Origins, Evolution, and Use, coordinated by Christopher A. Casey. 9 National Emergencies Act (NEA); P.L. 94-412, §201; 50 U.S.C. 1621. 10 IEEPA, §203; 50 U.S.C. 1702. Congressional Research Service 5 U.S. Sanctions on Russia One limitation on the role of Congress in establishing sanctions originates in the U.S. Constitution’s bill of attainder clause.11s bill of attainder clause.¹¹ Congress may not enact legislation that "“legislatively determines guilt and inflicts punishment upon an identifiable individual without provision of the protections of a judicial trial."¹²”12 In other words, Congress may enact legislation that broadly defines categories of sanctions targets and objectionable behavior, but it is left to the President to "“[determine] guilt and [inflict] punishment"”—that is, to populate the target categories with specific individuals and entities.

Sanctions Implementation

In the executive branch, several agencies have varying degrees of responsibility in implementing and administering sanctions. Primary agencies, broadly speaking, have responsibilities as follows:

•  Department of the Treasury'’s OFAC designates SDNs to be subject to the blocking of U.S.-based assets; designates non-SDNs for which investments or transactions may be subject to conditions or restrictions; prohibits transactions; licenses transactions relating to exports and investments (and limits those licenses); restricts access to U.S. financial services; restricts transactions related to travel, in limited circumstances; and (with regard to Russia sanctions) identifies entities for placement on the SSI List as subject to investment and trade limitations.
•  Department of State restricts visas, arms sales, and foreign aid; implements arms embargos required by the United Nations; prohibits the use of U.S. passports to travel, in limited circumstances; and downgrades or suspends diplomatic relations.
•  Department of Commerce'’s BIS restricts licenses for commercial exports, end users, and destinations.
•  Department of Defense restricts arms sales and other forms of military cooperation.
• cooperation.  Department of Justice investigates and prosecutes violations of sanctions and export laws.¹³

13 U.S. Sanctions on Russia

The United States imposes sanctions on Russia in accordance with several laws and executive orders. In 2012, the United States introduced a new sanctions regime on Russia in response to human rights abuses. In 2014, the United States introduced an extensive new sanctions regime on Russia in response to Russia's invasion of Ukraine. In 2016, the United States imposed sanctions on Russian individuals and entities for election interference and other malicious cyber-enabled activities. In 2017, legislation was enacted to strengthen existing sanctions authorities and establish new sanctions in response to Russia's invasion of Ukraine, malicious cyber-enabled activities, human rights abuses, and corruption. The United States also has imposed sanctions on Russian individuals and entities in response to the use of a chemical weapon, weapons proliferation, trade with North Korea in violation of U.N. Security Council requirements, support for the Syrian and Venezuelan governments, transnational crime, and international terrorism.

For an overview of Russia sanctions authorities and designations, see Appendix B.

Sergei Magnitsky Act and the Global Magnitsky Act

Sanctions Related to Russia's Invasion of Ukraine

Most OFAC designations of Russian individuals and entities have beenmaintains sanctions on Russia related to Russia’s 2014 invasion of Ukraine, malicious cyber activities and influence operations (including election interference), use of chemical weapons, human rights abuses, use of energy exports as a coercive or political tool, weapons proliferation, illicit trade with North Korea, support to the governments of Syria and Venezuela, and other activities. 11 “No Bill of Attainder or ex post facto Law Will Be Passed.” U.S. Constitution, Article I, §9, clause 3. 12 See out-of-print CRS Report R40826, Bills of Attainder: The Constitutional Implications of Congress Legislating Narrowly, available to congressional offices on request. 13 Other departments, bureaus, agencies, and offices of the executive branch also weigh in, but to a lesser extent. The Department of Homeland Security, Attorney General, and Federal Bureau of Investigation, for example, all might review decisions relating to visas; Customs and Border Protection has a role in monitoring imports; the Department of Energy has responsibilities related to export control of nuclear materials; and the National Security Council reviews foreign policy and national security determinations and executive orders as part of the interagency process. Congressional Research Service 6 link to page 51 link to page 14 link to page 51 link to page 14 link to page 51 U.S. Sanctions on Russia For an overview of Russia sanctions authorities and designations, see Appendix B. Sanctions Related to Russia’s Invasion of Ukraine OFAC has issued most U.S. sanctions designations of Russian individuals and entities in response to Russia'’s 2014 invasion and annexationoccupation of Ukraine'’s Crimea region and Russia's subsequent instigation of separatist conflict inparts of eastern Ukraine. In 2014, the Obama Administration said it would impose increasing costs on Russia, in coordination with the EU and others, until Russia "“abides by its international obligations and returns its military forces to their original bases and respects Ukraine'’s sovereignty and territorial integrity."²¹

”14 The United States has imposed sanctions related to Russia'’s invasion of Ukraine on more than 680 at least 735 individuals, entities, vessels, and aircraft by placing them on OFAC'sthat OFAC has placed on its Specially Designated Nationals List (SDN) or Sectoral Sanctions Identification List (SSI) (see Table 1 andand Table B-1). The basis for most of these sanctions is a series of four executive orders (E.O.s 13660, 13661, 13662, and 13685) that President Obama issued in 2014.15 In addition. In addition to Treasury-administered sanctions, the Department of Commerce'Commerce’s BIS denies export licenses for military, dual-use, or energy-related goods to designated end users, most of which also are subject to Treasury-administered sanctions. The basis for these sanctions is mainly a series of four executive orders (EOs 13660, 13661, 13662, and 13685) that President Obama issued in 2014.²²

Two of President Obama'’s Ukraine-related EOsE.O.s target specific objectionable behavior. EO E.O. 13660 provides for sanctions against those the President determines have undermined democratic processes or institutions in Ukraine; undermined Ukraine'’s peace, security, stability, sovereignty, or territorial integrity; misappropriated Ukrainian state assets; or illegally asserted governmental authority over any part of Ukraine. EOE.O. 13685 prohibits U.S. business, trade, or investment in occupied Crimea and provides for sanctions against those the President determines have operated in, or been the leader of an entity operating in, occupied Crimea.

The other two EOsE.O.s provide for sanctions against a broader range of targets. EOE.O. 13661 provides for sanctions against Russian government officials, those who offer them support, and those operating in the Russian arms sector. EOE.O. 13662 provides for sanctions against individuals and entities that operate in key sectors of the Russian economy, as determined by the Secretary of the Treasury.

Specially Designated Nationals

OFAC established four SDN listsprograms based on the four Ukraine-related EOsE.O.s: two lists for those found to have engaged in specific activities related to the destabilization and invasion of Ukraine, and two lists for broader groups of targets. As of January 20202022, OFAC has placed more than 390 designated at least 445 individuals, entities, vessels, and aircraft onunder the four Ukraine-related SDN listsprograms (see Table 1 andand Table B-1).

OFAC has drawn on EO OFAC draws on E.O. 13660 to designate individuals and entities for their role in destabilizing and invading Ukraine. Designees mainly include former Ukrainian officials (including ex- 14 White House, “Fact Sheet: Ukraine-Related Sanctions,” March 17, 2014. 15 The President declared that events in Ukraine constituted a national emergency in the first executive order; the subsequent three orders built on and expanded that initial declaration. E.O. 13660 must be extended annually to remain in force; the President extended it most recently on March 2, 2021. Executive Order (E.O.) 13660 of March 6, 2014, “Blocking Property of Certain Persons Contributing to the Situation in Ukraine,” 79 Federal Register 13493; E.O. 13661 of March 16 [17], 2014, “Blocking Property of Additional Persons Contributing to the Situation in Ukraine,” 79 Federal Register 15535; E.O. 13662 of March 20, 2014, “Blocking Property of Additional Persons Contributing to the Situation in Ukraine,” 79 Federal Register 16169; and E.O. 13685 of December 19, 2014, “Blocking Property of Certain Persons and Prohibiting Certain Transactions with Respect to the Crimea Region of Ukraine,” 79 Federal Register 77357. Congressional Research Service 7 link to page 19 U.S. Sanctions on Russia and invading Ukraine. Designees mainly include former Ukrainian officials (including ex-President Viktor Yanukovych and a former prime minister), de facto Ukrainian separatist officials in occupied Crimea and eastern Ukraine, Russia-based fighters and patrons, and associated companies or organizations.

OFAC has drawn on EO OFAC draws on E.O. 13685 to designate primarily Russian or Crimea-based companies and subsidiaries that operate in occupied Crimea (including individuals and entities involved in construction and operation of the Russia-Crimea railway and a prison in Crimea known as a site of human rights abuses). In September 2019, OFAC drew on E.O.. In September 2019, OFAC also drew on EO 13685 to designate nine individuals, entities, and vessels for evading Crimea-related sanctions in furtherance of an illicit scheme to deliver fuel to Russian forces in Syria.

OFAC has drawn on EO 13661 and EO 13662 OFAC draws on E.O. 13661 (and, in some cases, E.O. 13662) to designate a wider circle of Russian government officials, members of parliament, heads of state-owned companies, other prominent businesspeople and associates, including individuals the Department of the TreasuryTreasury Department has considered part of Russian President Vladimir Putin's "’s “inner circle,"” and related entities.²³

16 Pursuant to these E.O.s (and sometimes simultaneously pursuant to other authorities), OFAC also has designated officials and state-connected individuals and entities in response to other Russian activities, including malign influence operations worldwide and the poisoning and imprisonment of Russian opposition figure Alexei Navalny. Among the designated government officials and heads of state-owned companies are Russia's ’s minister of internal affairs, prosecutor general, and Security Council secretary,; directors of the Federal Security Service (FSB), Foreign Intelligence Service and(SVR), National Guard Troops, and the Federal Penitentiary Service; the chairs of both houses of parliament; and the chief executive officers of state-owned oil company Rosneft, gas company Gazprom, defense and technology conglomerate Rostec, and banks VTB and Gazprombank. OFAC also has drawn on EOE.O. 13661 to designate four Russian border guard officials for their role in Russia's Novembera 2018 attack against Ukrainian naval vessels and their crew in the Black Sea near occupied Crimea.

OFAC has designated several politically connected Russian billionaires (whom the Department of the Treasury refers to as oligarchs) and companies they own or control under EO 13661 and EO 13662.²⁴E.O. 13661 or E.O. 13662.17 Designees include 9 of Russia'’s wealthiest 100 individuals, including 34 of the top 20, as estimated in 2021 by Forbes.²⁵18 Of these 9 nine billionaires, 5five were designated in April 2018 as "“oligarchs … who profit from [Russia'’s] corrupt system."²⁶ Under EO 13661, OFAC also ”19 Under E.O. 13661 and other authorities, OFAC has designated Yevgeny Prigozhin, a wealthy state-connected businessperson alleged to be a lead financial backer of private military companies operating in Ukraine, Syria, and other countries. Prigozhin is also designated under other authorities for election interference operations in the United States and elsewhere.

The entities OFAC has designated include(PMCs) that have operated in Ukraine and elsewhere (see “Prigozhin Network” below). These PMCs include the Wagner Group, also subject to U.S. sanctions. OFAC has designated other holdings owned or controlled by SDNs. These holdings include Bank Rossiya, which the Department of the TreasuryTreasury Department has described as the "“personal bank"” of Russian senior officials;²⁷20 other privately held banks and financial services companies (e.g., SMP Bank and the 16 See, for example, U.S. Department of the Treasury, “Treasury Sanctions Russian Officials, Members of the Russian Leadership’s Inner Circle, And An Entity For Involvement In The Situation In Ukraine,” press release, March 20, 2014. 17 E.O. 13661, for being a Russian government official or supporting a senior government official, and E.O. 13662, for operating in the energy sector. 18 “The World’s Billionaires,” Forbes, 2021, at https://www.forbes.com/billionaires/list/#version:static_country:Russia. 19 U.S. Department of the Treasury, “Treasury Designates Russian Oligarchs, Officials, and Entities in Response to Worldwide Malign Activity,” press release, April 6, 2018. 20 U.S. Department of the Treasury, “Treasury Sanctions Russian Officials, Members Of The Russian Leadership’s Inner Circle, And An Entity For Involvement In The Situation In Ukraine,” press release, March 20, 2014. Congressional Research Service 8 link to page 29 U.S. Sanctions on Russia other privately held banks and financial services companies (e.g., SMP Bank and the Volga Group); gas pipeline construction company Stroygazmontazh; construction company Stroytransgaz; and vehicle manufacturer GAZ Group. Private aluminum company Rusal, electric company EuroSibEnergo, and the related En+ Group were delisted in January 2019 after being designated in April 2018the year before (for more, see "“Section 241 "Oligarch" List").

“Oligarch” List and Related Sanctions,” below). Designated entities also include several defense and arms firms, such as the state-owned United Shipbuilding Corporation, Almaz-Antey (air defense systems and missiles), Uralvagonzavod (tanks and other military equipment), NPO Mashinostroyenia (missiles and rockets), and several subsidiaries of the state-owned defense and hi-tech conglomerate Rostec, including the Kalashnikov Group (firearms).

Sectoral Sanctions Identifications

Prior to April 2018, OFAC used EO 13662 solely OFAC has used E.O. 13662 mainly as the basis for identifying entities for inclusion on the SSI List. Individuals and entities under U.S. jurisdiction are restricted from engaging in specific transactions with entities on the SSI List, which OFAC identifies as subject to one of four directives under the EOE.O. SSI restrictions apply to new equity investment and financing (other than 14-day lending) for identified entities in Russia'’s financial sector (Directive 1); new financing (other than 60-day lending) for identified entities in Russia'’s energy sector (Directive 2); and new financing (other than 30-day lending) for identified entities in Russia'’s defense sector (Directive 3).²⁸21 A fourth directive prohibits U.S. trade with identified entities related to the development of Russian deepwater, Arctic offshore, or shale projects that have the potential to produce oil and, amended as a result of requirements enacted in CRIEEA in 2017, such projects worldwide in which those entities have an ownership interest of at least 33% or a majority of voting interests.

As of January 20202022, OFAC has placed 13 major Russian companies and more than 275 of their subsidiaries and affiliates on the SSI List. The SSI List includes major state-owned companies in the financial, energy, and defense sectors; it does not include all companies in those sectors. The parent entities on the SSI List, under their respective directives, consist of the following:

• Four  Five large state-owned banks: (Sberbank, VTB Bank, Gazprombank, Rosselkhozbank) Rosselkhozbank, and VEB (rebranded VEB.RF in 2018), which "“acts as a development bank and payment agent for the Russian government";²⁹
• ”;22  State-owned oil companies Rosneft and Gazpromneft, pipeline company Transneft, and private gas producer Novatek;
•  State-owned defense and hi-tech conglomerate Rostec; and
•  For restrictions on transactions related to deepwater, Arctic offshore, or shale oil projects, Rosneft and Gazpromneft, private companies Lukoil and Surgutneftegaz, and state-owned energy company Gazprom (Gazpromneft's ’s parent company). 21 Directive 1 has been amended twice to narrow lending windows from, initially, 90 days (July 2014) to 30 days (September 2014) to 14 days (September 2017). The lending window in Directive 2 has been narrowed once, from 90 days (July 2014) to 60 days (September 2017). Directives are available at https://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx. 22 The Administration also designated the Bank of Moscow, which later became a subsidiary of VTB Bank. U.S. Department of the Treasury, “Announcement of Treasury Sanctions on Entities Within the Financial Services and Energy Sectors of Russia, Against Arms or Related Materiel Entities, and those Undermining Ukraine’s Sovereignty,” press release, July 16, 2014. Congressional Research Service 9 link to page 14 link to page 32 link to page 58 U.S. Sanctions on Russia parent company).

Ukraine-Related Legislation

Ukraine-Related Legislation In addition to issuing four Ukraine-related executive orders in 2014, President Obama signed into law the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act (SSIDES) on April 3, 2014, and the Ukraine Freedom Support Act (UFSA) on December 18, 2014. SSIDES was introduced in the Senate on March 12, 2014, six days after President Obama issued the first Ukraine-related EOE.O., declaring a national emergency with respect to Ukraine. The President signed UFSA into law the day before he issued his fourth Ukraine-related EO, E.O., prohibiting trade and investment with occupied Crimea. CRIEEA, which President Trump signed into law on August 2, 2017, amended SSIDES and UFSA (for more on CRIEEA, see ", among other measures (see Table 1 and “Countering Russian Influence in Europe and Eurasia Act of 2017," below).

” text box, below). Both SSIDES and UFSA expandedexpand on the actions the Obama Administration took in response to Russia'Russia’s invasion of Ukraine. President Obama did not cite SSIDES or UFSA as an authority for designations or other sanctions actions, however.23 The Trump Administration issued three human rights-related designations pursuant to SSIDES. designations or other sanctions actions.³⁰ In November 2018, President Trump cited SSIDES, as amended by CRIEEA (Section 228), to designate two Ukrainian individuals and one entity for committing serious human rights abuses in territories forcibly occupied or controlled by Russia. President Trump has not cited UFSA as an authority for any sanctions designations.

Some sanctions authorities in SSIDES and UFSA overlap with steps taken by the President in issuing executive ordersE.O.s under emergency authorities. Many individuals and entities OFAC designated for their role in destabilizing Ukraine, for example, could have been designated pursuant to SSIDES. Similarly, some of the individuals OFAC designated in April 2018 as "“oligarchs and elites who profit from [Russia'’s] corrupt system"” potentially could have been designated pursuant to the authority in SSIDES that provides for sanctions against those responsible for significant corruption.³¹24 In addition, Russian arms exporter Rosoboronexport, subject to sanctions under UFSA, is subject to sanctions under other authorities (see "“Weapons Proliferation").

”). SSIDES and UFSA contain additional sanctions provisions that the executive branch could use. These include sanctions against Russian individuals and entities for corruption, arms transfers to Syria and separatist territories, and energy export cutoffs. They also include potentially wide-reaching secondary sanctions against foreign individuals and entities that facilitate significant transactions for Russia sanctions designees, help them to evade sanctions, or make significant investments in certain oil projects in Russia (for details, see Appendix C). Table 1. U.S. Sanctions Related to Russia’s Invasion of Ukraine (authorities, targets, and Treasury designees) Designations Authorities Targets (as of 1/2022) Executive Order (E.O.) Those responsible for undermining Ukraine’s democracy; 128 individuals, 24 13660; Countering threatening its peace, security, stability, sovereignty, or entities Russian Influence in territorial integrity; misappropriating assets; and/or il egally Europe and Eurasia Act asserting government authority. of 2017 (CRIEEA; P.L. 115-44, Title II; 22 U.S.C. 9501 et seq.) 23 In his signing statement, President Obama said the Administration did “not intend to impose sanctions under this law, but the Act gives the Administration additional authorities that could be utilized, if circumstances warranted.” White House, “Statement by the President on the Ukraine Freedom Support Act,” December 18, 2014. 24 U.S. Department of the Treasury, “Treasury Designates Russian Oligarchs, Officials, and Entities in Response to Worldwide Malign Activity,” press release, April 6, 2018. Congressional Research Service 10 U.S. Sanctions on Russia Designations Authorities Targets (as of 1/2022) E.O. 13661; P.L. 115-44 Russian government officials; those operating in Russia’s arms 109 individuals, 78 or related materiel sector; entities owned or control ed by a entities, 3 aircraft, 1 investments in certain oil projects in Russia (for details, see text box entitled "Sanctions in Ukraine-Related Legislation," below).

Election Interference and Other Malicious Cyber-Enabled Activities

Congressional Research Service 11 U.S. Sanctions on Russia Election Interference and Other Malicious Cyber-Enabled or Intelligence Activities Sanctions Authorities The executive branch draws on national emergency authorities and other legislation to impose sanctions for a range of malicious cyber-enabled activities, influence operations (including election interference), and other intelligence activities in the United States or elsewhere, including and other activities the United States has attributed to the Russian government. The relevant authorities are as follows: E.O. 13694, as amended by E.O. 13757. On April 1, 2015, President Obama issued EOE.O. 13694, invoking national emergency authorities to declare that "“the increasing prevalence and severity of malicious cyber-enabled activities originating from, or directed by persons located … outside the United States, constitute an unusual and extraordinary threat." EO” E.O. 13694 targetedtargets those who engage in cyberattacks (1) against critical infrastructure, (2) for financial or commercial gain, or (3) to significantly disrupt the availability of a computer or network.³²

25 On December 28, 2016, President Obama issued EOE.O. 13757, which amended EOE.O. 13694 to establish sanctions against those engaged in "“tampering with, altering, or causing a misappropriation of information with the purpose or effect of interfering with or undermining election processes or institutions."³³ President Obama issued this EO almost three months after the Department of Homeland Security and”26 Nine days after President Obama issued E.O. 13757, the Office of the Director of National Intelligence (ODNI)Intelligence (ODNI) issued a joint statement, on October 7, 2016, which said the U.S. intelligence community was "confident that the Russian Government directed the recent compromises of e-mails from US persons and institutions, including from US political organizations" and that "these thefts and disclosures are intended to interfere with the US election process."³⁴

Nine days after President Obama issued EO 13757, the ODNI released an unclassified Intelligence Community Assessment on Russian activities and intentions related to the 2016 U.S. presidential election. The assessment stated that the Central Intelligence Agency, the Federal Bureau of Investigation, and the National Security Agency had "“high confidence"” that Russian President Vladimir Putin had "“ordered an influence campaign in 2016 aimed at the U.S. presidential election."³⁵

”27 CRIEEA, Section 224. CRIEEA, enacted in August 2017, codified EOE.O. 13694, as amended, and, in Section 224, enlargedexpanded the scope of cyber-related activities subject to sanctions to include a range of activities conducted on behalf of the Russian government that undermine "“cybersecurity against any person, including a democratic institution, or government" (for more on CRIEEA, see "Countering Russian Influence in Europe and Eurasia Act of 2017," below).³⁶

On September 12, 2018, President Trump issued EO.”28 25 E.O. 13694 did not target a specific state, entity, or individual. President Obama issued the E.O. four months after the Sony Pictures hack, which the U.S. intelligence community assessed had originated in North Korea, and 10 months after the U.S. Department of Justice indicted several Chinese military officers for cyber-related espionage. E.O. 13694 of April 1, 2015, “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities,” 80 Federal Register 18077. E.O. 13694, as amended, must be extended annually to remain in force; the President extended it most recently on March 29, 2021. 26 E.O. 13757 of December 28, 2016, “Taking Additional Steps to Address the National Emergency with Respect to Significant Malicious Cyber-Enabled Activities,” 82 Federal Register 1. 27 Office of the Director of National Intelligence, Assessing Russian Activities and Intentions in Recent U.S. Elections, Intelligence Community Assessment 2017-01D, January 6, 2017. 28 The Countering Russian Influence in Europe and Eurasia Act of 2017, as amended (CRIEEA; P.L. 115-44, Title II, §224; 22 U.S.C. 9524(d)) defines these activities to include the following: (1) significant efforts—(A) to deny access to or degrade, disrupt, or destroy an information and communications technology system or network; or (B) to exfiltrate, degrade, corrupt, destroy, or release information from such a system or network without authorization for purposes of—(i) conducting influence operations; or (ii) causing a significant misappropriation of funds, economic resources, trade secrets, personal identifications, or financial information for commercial or Congressional Research Service 12 U.S. Sanctions on Russia E.O. 13848. On September 12, 2018, President Trump issued E.O. 13848, invoking new national emergency authorities to declare that "“the ability of persons located … outside the United States to interfere in or undermine public confidence in United States elections, including through the unauthorized accessing of election and campaign infrastructure or the covert distribution of propaganda and disinformation, constitutes an unusual and extraordinary threat."³⁷ EO”29 E.O. 13848 also states that "“the proliferation of digital devices and internet-based communications has created significant vulnerabilities and magnified the scope and intensity of the threat of foreign interference, as illustrated in the 2017 Intelligence Community Assessment."interference.” In addition, it states that "“there has been no evidence of a foreign power altering the outcome or vote tabulation in any United States election."

EO” E.O. 13848 provides for sanctions against foreign individuals and entities that have "“directly or indirectly engaged in, sponsored, concealed or otherwise been complicit in foreign interference in a United States election."” The EOE.O. requires the Director of National Intelligence to make an initial assessment regarding foreign interference within 45 days of an election and the Attorney General and Secretary of Homeland Security to issue a second report regarding the impact of such interference on election and campaign infrastructure within another 45 days.30 In addition, the EOE.O. requires the Secretary of State and the Secretary of the Treasury to recommend to the President the appropriateness of additional sanctions, including against the largest business entities of the country determined to have interfered in elections, including at least one each from the financial services, defense, energy, technology, and transportation sectors. CRIEEA, Section 231. CRIEEA, Section 231, also responds to malicious cyber-enabled activities by establishing sanctions against those who engage in “significant transactions” with the Russian defense or intelligence sectors, including arms sales. E.O. 14024. On April 15, 2021, President Biden issued E.O. 14024 to impose sanctions against those responsible for or who have engaged in malicious cyber-enabled activities, election interference, or the undermining of democratic processes or institutions on behalf of the Russian government, among other “harmful foreign activities.”31 The other “harmful foreign activities” included in E.O. 14024 include transnational corruption; the unlawful killing or harming of U.S. persons or U.S. ally or partner nationals; activities that “undermine the peace, security, political stability, or territorial integrity of the United States, its allies, or its partners”; and the circumvention of U.S. sanctions. The E.O. targets Russian government officials and entities (and officials’ spouses and families); persons operating in Russia’s technology, defense, and related materiel or other sectors; and Russian persons who support governments subject to U.S. sanctions or who disrupt energy supplies to Europe or Asia. competitive advantage or private financial gain; (2) significant destructive malware attacks; and (3) significant denial of service activities. 29 Executive Order 13848 of September 12, 2018, “Imposing Certain Sanctions in the Event of Foreign Interference in a United States Election,” 83 Federal Register 46843. E.O. 13848 must be extended annually to remain in force; the President extended it most recently on September 7, 2021. 30 The FY2020 National Defense Authorization Act (NDAA; P.L. 116-92, §5304(a)(1); 50 U.S.C. 3371) includes a separate requirement for the Director of National Intelligence, in coordination with the Under Secretary of Homeland Security for Intelligence and Analysis and the Director of the Federal Bureau of Investigation, to “make publicly available on an internet website an advisory report on foreign counterintelligence and cybersecurity threats to campaigns of candidates for Federal office.” 31 Executive Order 14024 of April 15, 2021, “Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation,” 86 Federal Register 20249. Congressional Research Service 13 U.S. Sanctions on Russia Related Actions32 U.S. Election Interference Under one or more of these authorities, the United States has designated at least 68the financial services, defense, energy, technology, and transportation sectors.

Related Actions

In December 2018, the Administration designated nine GRU officers under Section 224 and two individuals and four entities under EO 13694, as amended,related entities, vessels, and aircraft for activities related to electionRussian interference. All the GRU officers were indicted previously by the Department of Justice Special Counsel' in U.S. elections. Several of the designated individuals also have been indicted by the Department of Justice for related crimes. These designations include the following:  Russia’s leading intelligence agency (Federal Security Service, or FSB), military intelligence agency (Main Intelligence Directorate, or GRU), four GRU officers, and three companies that allegedly facilitated election-related cyberattacks (designated in December 2016).33  The Internet Research Agency (IRA), 12 of its employees, alleged financial backer Yevgeny Prigozhin, and two of Prigozhin’s companies. All of these were indicted previously by the Department of Justice Special Counsel’s Office for related crimes.³⁹ The six other designees were " (March 2018).34  Nine GRU officers indicted previously by the Department of Justice Special Counsel’s Office for crimes related to election interference (December 2018).35  Six designees “related to Project Lakhta, a broad Russian effort that includes the IRA." ⁴⁰ The designees included a Project Lakhta employee IRA.” 36 The designees included an individual whom the Department of Justice charged in September 2018 for conspiracy to defraud the United States related to Project Lakhta's efforts "“to interfere in the U.S. political system, including the 2018 midterm election."⁴¹

election” (December 2018).37  In response to Russian efforts to interfere in the 2018 U.S. midterm elections, OFAC issued the first designations under E.O. 13848. Designees included the IRA, Prigozhin, and four IRA employees (all previously designated under E.O. 13694, as amended), as well as two other IRA employees, three Prigozhin-owned aircraft and a yacht, and three associated front companies (September 2019). 32 For more on Russian intelligence agencies and their cyber operations, see CRS Report R46616, Russian Military Intelligence: Background and Issues for Congress, by Andrew S. Bowen, and CRS In Focus IF11718, Russian Cyber Units, by Andrew S. Bowen. 33 At this time, the Administration also declared 35 Russian diplomatic personnel personae non grata in response to what Obama Administration officials characterized as increased harassment of U.S. diplomatic personnel in Russia. The Administration also denied Russian officials access to two Russian government-owned compounds, located in Maryland and New York, which President Obama said Russia was using for intelligence-related purposes. White House, “Fact Sheet: Actions in Response to Russian Malicious Cyber Activity and Harassment,” December 29, 2016; and White House, “Statement by the President on Actions in Response to Russian Malicious Cyber Activity and Harassment,” December 29, 2016. 34 For the Special Counsel’s indictment, see U.S. Department of Justice, “Grand Jury Indicts Thirteen Russian Individuals and Three Russian Companies for Scheme to Interfere in the United States Political System,” press release, February 16, 2018. 35 For the Special Counsel’s indictment, see U.S. Department of Justice, “Grand Jury Indicts 12 Russian Intelligence Officers for Hacking Offenses Related to the 2016 Election,” press release, July 13, 2018. 36 U.S. Department of the Treasury, “Treasury Targets Russian Operatives over Election Interference, World Anti-Doping Agency Hacking, and Other Malign Activities,” press release, December 19, 2018. 37 U.S. Department of Justice, “Russian National Charged with Interfering in U.S. Political System,” press release, October 19, 2018. Congressional Research Service 14 U.S. Sanctions on Russia  Three IRA employees for supporting the IRA’s cryptocurrency accounts (September 2020).  Ukrainian Member of Parliament Andrii Derkach in response to Russian-linked efforts to interfere in the 2020 U.S. presidential election. The Treasury Department characterized Derkach as “an active Russian agent for over a decade” (September 2020).38  Seven individuals and four entities in Ukraine that OFAC determined to be “part of a Russia-linked foreign influence network” associated with Derkach (January 2021).39  At least four individuals and entities for “attempt[ing] to influence the 2020 U.S. presidential election at the direction of the leadership of the Russian government.” Designees included a Russian first deputy presidential chief of staff, a political consultant Treasury said also interfered in the 2016 U.S. presidential election, and two Russian intelligence-controlled “disinformation outlets.”40 OFAC also designated three other intelligence-controlled outlets and a related individual for broader disinformation activities (April 2021). Prigozhin Network Since 2016, OFAC has imposed sanctions on a network of individuals and entities linked to Russian financier Yevgeny Prigozhin. In addition to the above-mentioned sanctions imposed in response to U.S. election interference, OFAC has applied sanctions to Prigozhin, two of his companies, and the allegedly Prigozhin-financed PMC Wagner Group and its leader for activities related to Russia’s invasion of Ukraine. In July and September 2020, OFAC imposed sanctions on 13 Prigozhin-linked individuals and entities in Sudan, the Central African Republic, Hong Kong, and Thailand. OFAC said these designees had “directly facilitated Prigozhin’s global operations,” exploited natural resources in Sudan and the Central African Republic, “attempted to suppress and discredit protestors seeking democratic reforms in Sudan,” or enabled Prigozhin to evade U.S. sanctions.41 In April 2021, OFAC imposed sanctions on 24 additional Prigozhin-linked individuals and entities for facilitating global influence operations, including in Africa and Europe, evading sanctions, and helping IRA personnel commit identity fraud. Other Malicious Cyber-Enabled and Intelligence Activities OFAC has designated individuals and entities for malicious Russian cyber-enabled and intelligence activities unrelated to election interference. Pursuant to Section 224, OFAC designated in March 2018 the FSB, GRU, and four GRU officers (all previously designated under E.O. 13694, as amended, for U.S. election interference), as well as two other GRU officers, for 38 U.S. Department of the Treasury, “Treasury Sanctions Russia-linked Election Interference Actors,” press release, September 10, 2021. 39 U.S. Department of the Treasury, “Treasury Takes Further Action Against Russian-linked Actors,” press release, January 11, 2021. 40 U.S. Department of the Treasury, “Treasury Escalates Sanctions Against the Russian Government’s Attempts to Influence U.S. Elections,” press release, April 15, 2021. 41 U.S. Department of the Treasury, “Treasury Targets Financier’s Illicit Sanctions Evasion Activity,” July 15, 2020; and U.S. Department of the Treasury, “Treasury Increases Pressure on Russian Financier,” September 23, 2020. Congressional Research Service 15 U.S. Sanctions on Russia “destructive cyberattacks.” These cyberattacks included the 2017 “NotPetya” ransomware attack the Treasury Department called “the most destructive and costly cyberattack in history.”42 In December 2018, OFAC designated four more GRU officers for cyber operations against the World Anti-Doping Agency and/or the Organization for the Prohibition of Chemical Weapons (OPCW). These officers have been indicted by the Department of Justice for related crimes.43 OFAC has designated individuals and entities for facilitating intelligence activities and sanctions evasion for the FSB and other Russian intelligence services. In June and August 2018, OFAC designated under EOE.O. 13694, as amended, five individuals and seven entities that the Department of the Treasury Department referred to as FSB enablers. One of these entities, Divetechnoservices, "“procured a variety of underwater equipment and diving systems for Russian government agencies"” and "“was awarded a contract to procure a submersible craft." The Department of the Treasury” The Treasury Department noted that Russia "“has been active in tracking undersea communications cables, which carry the bulk of the world's ’s telecommunications data.”44 In September 2020, OFAC designated one company and four related individuals and entities for conducting related trade with Divetechnoservices, another underwater technology company, and four related individuals. In October 2020, OFAC designated a Russian government research institution for allegedly supporting a Triton malware attack that targets industrial safety systems and “has been deployed against U.S. partners in the Middle East.”45 In April 2021, under the new E.O. 14024, OFAC designated six Russian technology companies for supporting the GRU, SVR, and FSB. In announcing the sanctions, the Treasury Department said Russia’s intelligence services “have executed some of the most dangerous and disruptive cyber attacks in recent history, including the SolarWinds cyber attack [that compromised victims in] the financial sector, critical infrastructure, government networks, and many others.”46 OFAC has designated Russian individuals and entities for financial cybercrimes. telecommunications data."⁴⁶

In December 2019, OFAC designated a Russian cybercriminal organization known as Evil Corp and 23 related individuals and entities under EOE.O. 13694, as amended. The Department of the TreasuryTreasury Department alleged that Evil Corp deployed malware "“to infect computers and harvest login credentials from hundreds of banks and financial institutions in over 40 countries, causing more than $100 million in theft."⁴⁸ ”47 The same day, the Department of Justice announced related charges against two alleged leaders of Evil Corp. 42 U.S. Department of the Treasury, “Treasury Sanctions Russian Cyber Actors for Interference with the 2016 U.S. Elections and Malicious Cyber-Attacks,” press release, March 15, 2018. On the NotPetya attack, see Andy Greenberg, “The Untold Story of NotPetya, The Most Devastating Cyberattack in History,” Wired, August 22, 2018. 43 U.S. Department of Justice, “U.S. Charges Russian GRU Officers with International Hacking and Related Influence and Disinformation Operations,” press release, October 4, 2018. 44 U.S. Department of the Treasury, “Treasury Sanctions Russian Federal Security Service Enablers,” press release, June 11, 2018. Also see Greg Walters, “The U.S. Is Worried About Russian Submarines Spying on the Internet,” Vice News, June 11, 2018. 45 U.S. Department of the Treasury, “Treasury Sanctions Russian Government Research Institution Connected to the Triton Malware,” press release, October 23, 2020. 46 U.S. Department of the Treasury, “Treasury Sanctions Russia with Sweeping New Sanctions Authority,” press release, April 15, 2021. 47 Three associated entities that OFAC designated were delisted eight days later. U.S. Department of the Treasury, “Treasury Sanctions Evil Corp, the Russia-Based Cybercriminal Group Behind Dridex Malware,” press release, December 5, 2019; and Meduza, “U.S. Treasury Removes Three Russian Companies with Alleged Ties to Hacker Collective Evil Corp from Sanctions List,” December 13, 2019. Congressional Research Service 16 U.S. Sanctions on Russia OFAC has imposed cybercrime-related sanctions on two individuals for illicit financial-related activities (in December 2016), two individuals for involvement in a scheme targeting holders of virtual currency assets (September 2020), a virtual currency exchange (the first such entity to be designated by OFAC) for “facilitating financial transactions for ransomware actors” (September 2021), and related ransomware actors (November 2021).48 Arms Sales Also in response to malicious cyber-enabled activities, the U.S. government has imposed Evil Corp.

Also in response to malicious cyber-enabled activities, in September 2018, the Administration imposed its first secondary sanctions pursuant to Section 231 of CRIEEA, targeting those engaged in "“significant transactions"transactions” with the Russian defense or intelligence sectors., including arms sales. In October 2017, the State Department issued initial guidance regarding its implementation of Section 231 sanctions. It indicated it would examine “a wide range of factors ... in looking at any individual case” to determine whether a “significant transaction” had occurred. These factors “may include, but are not limited to, the significance of the transaction to U.S. national security and foreign policy interests, in particular whether it has a significant adverse impact on such interests; the nature and magnitude of the transaction; and the relation and significance of the transaction to the defense or intelligence sector of the Russian government.”49 In August 2018, then-U.S. Assistant Secretary of State Wess Mitchell said the threat of Section 231 sanctions had led to some $8-$10 billion in “foreclosed arms deals.”50 OFAC has imposed Section 231 sanctions in response to significant arms purchases by two countries, China and Turkey. In September 2018, OFAC designated the Equipment Development Department of China'’s Central Military Commission, as well as its director, for taking delivery of 10 Su-35 combat aircraft in December 2017 and S-400 surface-to-air missile system-related equipment in 2018.⁴⁹

In December 2020, OFAC designated Turkey’s Presidency of Defense Industries, its head, and related officers for taking delivery of S-400 surface-to-air missile system-related equipment.51 CRIEEA grants the President authority to waive the application of sanctions for national security reasons, but this waiver is subject to congressional review under Section 216 of the act. As originally enacted, Section 231 authorized the President to waive the initial application of sanctions for national security reasons or to “further the enforcement of this title,” but only if the President certified that Russia had “made significant efforts to reduce the number and intensity of cyber intrusions.” In addition, the President could delay the imposition of sanctions, if the President certified that an individual or entity was “substantially reducing the number of significant transactions” it makes with Russia’s defense or intelligence sector. 48 U.S. Department of the Treasury, “Treasury Takes Robust Actions to Counter Ransomware,” press release, September 21, 2021. 49 U.S. Department of State, “Briefing on Sanctions with Respect to Russia’s Defense and Intelligence Sectors Under Section 231 of the Countering America’s Adversaries Through Sanctions Act of 2017,” October 27, 2017; and U.S. Department of State, “Public Guidance on Sanctions with Respect to Russia’s Defense and Intelligence Sectors Under Section 231 of the Countering America’s Adversaries Through Sanctions Act of 2017,” updated September 20, 2018. 50 Testimony of A. Wess Mitchell, in U.S. Congress, Senate Committee on Foreign Relations, U.S.-Russia Relations, hearings, 115th Cong., 2nd sess., August 21, 2018, transcript at http://www.cq.com/doc/congressionaltranscripts-5378064. 51 In both cases, the Secretary of State, in consultation with the Secretary of the Treasury, selected five specific sanctions, pursuant to CRIEEA, to impose on the two defense agencies. Section 231 of CRIEEA requires the President to impose at least 5 of 12 sanctions described in Section 235 on individuals and entities that the President determines have engaged in significant transactions with Russia’s defense or intelligence sector. Congressional Research Service 17 U.S. Sanctions on Russia Congress amended Section 231 in the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (P.L. 115-232, §1294). The amendment provides for a national security waiver that does not require congressional review but does require the President to certify a transaction would not (1) be with an entity that directly participated in or facilitated cyber intrusions, (2) endanger the United States’ multilateral alliances or ongoing operations, (3) increase the risk of compromising U.S. defense systems, or (4) negatively impact defense cooperation with the country in question. The President also must certify that the country is taking steps to reduce the share of Russian-produced arms and equipment in its total inventory or is cooperating with the United States on other matters critical to U.S. national security. In addition, the executive branch fulfills a Section 231 reporting requirement to “specify the persons that are part of, or operate for or on behalf of, [Russia’s] defense and intelligence sectors.”52 The State Department initially stated that the entities on the list were not subject to sanctions but that secondary sanctions could be imposed on individuals and entities “that are determined to knowingly engage in a significant transaction with a person specified in the Guidance on or after the date of enactment of the Act.”53 The State Department expanded and formalized the list as the List of Specified Persons in September 2018; in doing so, the State Department indicated that “any person who knowingly engages in a significant transaction with any of these persons is subject to mandatory sanctions under [CRIEEA] section 231.”54 Countering Russian Influence in Europe and Eurasia Act of 2017 Countering Russian Influence in Europe and Eurasia Act of 2017

On August 2, 2017, President Trump signed the Countering America'’s Adversaries Through Sanctions Act of 2017 (CAATSA, P.L. 115-44), which includes as Title II the Countering Russian Influence in Europe and Eurasia Act of 2017 (CRIEEA).⁵⁰, 22 U.S.C. 9501 et seq.). CRIEEA codifies Ukraine-related and cyber-related EOsE.O.s (discussed above), strengthens sanctions authorities initiated in Ukraine-related EOsE.O.s and legislation, and establishesidentifies several new sanctions targets. It also establishes congressional review of any action the President takes to ease or lift a variety of sanctions imposed on Russia. In September 2018, President Trump issued EOE.O. 13849 establishing the means to implement certain sanctions provided for in CRIEEA (and UFSA, as amended).⁵¹

As of January 2020, the Trump Administration has made 29the Ukraine Freedom Support Act of 2014, as amended [UFSA; P.L. 113-272; 22 U.S.C. 8921 et seq.]). As of January 2022, OFAC has issued 44 designations based on new sanctions authorities in CRIEEA, relating to cyberattacks and/or GRU affiliation (§224, 24 undermining cybersecurity and/or affiliation with Russian intelligence services subject to U.S. sanctions (§224, 32 designations), human rights abuses (§228, amending SSIDES, 3 designations), and arms sales (§231arms sales (§231, 7 designations), and export pipeline development (§232, 2 designations). These designations are discussed in previousthe relevant sections of this report.

Some Members of Congress have called on the President to make more designations based on CRIEEA's ’s mandatory sanctions provisions. As of January 2020, the Administration has not imposed sanctions2022, OFAC has not issued designations under other CRIEEA authorities (§§225-228, 232-234). The Administration could use these authorities to target the following:

• significantfol owing:  Significant foreign investment in deepwater, Arctic offshore, or shale oil projects within Russia (§225, amending UFSA);
• foreign  Foreign financial institutions that facilitate certain transactions for Russia'’s defense or energy sectors, or for those subject to sanctions related to Russia'’s invasion of Ukraine (§226, amending UFSA);
• those  Those who engage in significant corruption (§227, amending UFSA);
• sanctions  Sanctions evaders and foreign persons that facilitate significant transactions for those subject to sanctions on Russia (§228, amending SSIDES);
• investment in Russia's energy export pipelines (§232);
• investment (or facilitating investment) that contributes to the privatization of Russia's state-owned assets "in a manner that unjustly benefits" government officials and associates (§233); and
• any foreign person who supports or facilitates Syria' 52 U.S. Department of State, “CAATSA Section 231(e) Defense and Intelligence Sectors of the Government of the Russian Federation,” updated March 2, 2021. 53 U.S. Department of State, “Public Guidance on Sanctions with Respect to Russia’s Defense and Intelligence Sectors Under Section 231 of the Countering America’s Adversaries Through Sanctions Act of 2017,” updated September 20, 2018. 54 U.S. Department of State, “CAATSA Section 231: ‘Addition of 33 Entities and Individuals to the List of Specified Persons and Imposition of Sanctions on the Equipment Development Department,’” September 20, 2018. Congressional Research Service 18 U.S. Sanctions on Russia  Investment (or facilitating investment) that contributes to the privatization of Russia’s state-owned assets “in a manner that unjustly benefits” government officials and associates (§233); and  Any foreign person who supports or facilitates Syria’s acquiring or developing a variety of advanced or prohibited weapons and defense articles, including weapons of mass destruction (§234).

Issues Related to CRIEEA Implementation

Section 231 Sanctions on Transactions with Russia's Defense and Intelligence Sectors

In October 2017, the State Department issued initial guidance regarding its implementation of Section 231 sanctions. It indicated it would examine "a wide range of factors ... in looking at any individual case" to determine whether a "significant transaction" had occurred. These factors "may include, but are not limited to, the significance of the transaction to U.S. national security and foreign policy interests, in particular whether it has a significant adverse impact on such interests; the nature and magnitude of the transaction; and the relation and significance of the transaction to the defense or intelligence sector of the Russian government."⁵⁴

Potential Section 231 Sanctions on Turkey.⁶³ In December 2017, Turkey and Russia reportedly signed an agreement for Turkey to purchase an S-400 surface-to-air missile system from Russia, in a deal worth $2.5 billion, with a portion of the total cost to be financed by a Russian loan.⁶⁴ In July 2019, Turkey began taking delivery of system components, and Turkish President Recep Tayyip Erdogan said the system would be fully deployed by April 2020.⁶⁵ In November 2019, the head of Turkey's defense procurement agency said the delivery of some components may be delayed over talks on technology sharing and joint production.⁶⁶

As of January 2020, the Trump Administration has neither imposed Section 231 sanctions on Turkey for its acquisition of the S-400 system nor issued a national security waiver to avert sanctions. The acquisition has led to the U.S. removal of Turkey from participation in the F-35 Joint Strike Fighter program.⁶⁷ In July 2019, President Trump reportedly asked a group of Senators for flexibility in sanctions implementation as he considered pursuing a deal potentially allowing Turkey to remain in the F-35 program if it (1) agreed not to use the S-400 and (2) acquired a U.S. Patriot air defense system.⁶⁸ Some Members of Congress have introduced legislation, largely in response to Turkey's 2019 military incursion into northern Syria, calling on the President to impose Section 231 sanctions in response to Turkey's S-400 acquisition or a determination as to whether the acquisition constitutes a significant transaction pursuant to Section 231.⁶⁹

Section 241 "Oligarch" List

CRIEEA, in Section 241, requires the Administration to submit a report to Congress that includes "an identification of any indices of corruption" among " Source: E.O. 13849 of September 20, 2018, “Authorizing the Implementation of Certain Sanctions Set Forth in the Countering America’s Adversaries Through Sanctions Act,” 83 Federal Register 48195. Use of a Chemical Weapon CBW Act Sanctions The Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act; P.L. 102-182, Title III; 22 U.S.C. 5601 et seq.) provides for sanctions against the government of a foreign country that the Secretary of State determines has used a chemical weapon in contravention of international law or against its own nationals. When such a finding is made, the CBW Act first requires the President (delegating authority to the Secretary of State) to, forthwith,  Terminate foreign assistance other than that which addresses urgent humanitarian situations or provides food or other agricultural products;  Terminate arms sales;  Terminate export licenses for U.S. Munitions List items;  Terminate foreign military financing;  Deny credit, credit guarantees, or other financial assistance from the U.S. government, including Export-Import Bank programs; and  Deny export licenses for goods or technology controlled for national security reasons (the Commodity Control List).55 Within three months after the initial determination, the CBW Act requires the President to impose at least three additional restrictions unless he determines and certifies to Congress that the government in question  “Is no longer using chemical or biological weapons in violation of international law or using lethal chemical or biological weapons against its own nationals”;  “Has provided reliable assurances that it will not in the future engage in any such activities”; and  “Is willing to allow on-site inspections by United Nations observers or other internationally recognized, impartial observers, or other reliable means exist, to ensure that that government is not using chemical or biological weapons in 55 CBW Act, §307(a); 22 U.S.C. 5605(a). President Clinton delegated the authority to make determinations and exercise waiver authority to the Secretary of State. Based on the Secretary of State’s determinations, the authority to restrict certain imports or exports is delegated to, respectively, the Secretary of the Treasury and the Secretary of Commerce. Executive Order 12851 of June 11, 1993, “Administration of Proliferation Sanctions, Middle East Arms Control, and Related Congressional Reporting Responsibilities,” 58 Federal Register 33181. Congressional Research Service 19 U.S. Sanctions on Russia violation of international law and is not using lethal chemical or biological weapons against its own nationals.... ”56 The CBW Act’s menu of possible second-round sanctions includes the authority to  Oppose loans or financial or technical assistance by international financial institutions;  Prohibit U.S. banks from making loans or providing credit to the violating government, except for the purchase of food or other agricultural products;  Prohibit exports of other goods and technology, except food and other agricultural products;  Restrict importation into the United States of articles that are the growth, product, or manufacture of the violating government;  Downgrade or suspend diplomatic relations; and  set in motion the suspension of foreign air carriers owned or controlled by the violating government “to engage in foreign air transportation to or from the United States.”57 The CBW Act authorizes the President to waive sanctions if the President finds it essential to U.S. national security interests and notifies Congress at least 15 days in advance. The President also may waive sanctions if the President finds that the violating government has undergone fundamental changes in leadership or policies (and notifies Congress at least 20 days in advance).58 CBW-related sanctions remain in place for at least a year. The sanctions may be removed only after the President determines and certifies to Congress that the three conditions stated above have been met and that the violating government is making restitution to those affected by the use of the chemical weapon. Poisoning of Sergei Skripal On August 6, 2018, then-Secretary of State Michael Pompeo determined that in March 2018, the Russian government used a chemical weapon in the UK in contravention of international law. The primary victims were British citizen Sergei Skripal, a former Russian military intelligence officer once imprisoned in Russia for allegedly working as a UK double agent, and his daughter. This finding triggered the CBW Act.59 Russian authorities denied involvement in the attack or possession of chemical weapons. On August 27, 2018, the State Department announced the imposition of a first round of CBW Act sanctions but invoked national security waiver authority to allow for the continuation of  Foreign assistance; 56 CBW Act, §307(b)(1); 22 U.S.C. 5605(b)(1). 57 CBW Act, §307(b)(2); 22 U.S.C. 5605(b)(2). 58 CBW Act, §307(d)(1)(B); 22 U.S.C. 5605(d)(1)(B). 59 The CBW Act has been invoked on two other occasions. In 2013, the State Department determined that the government of Syria had used chemical weapons but for national security reasons sanctions decisions would be applied on a case-by-case basis. In 2018, the Secretary of State determined that the government of North Korea was responsible for a lethal 2017 nerve agent attack on the half-brother of North Korean leader Kim Jong-un, in Malaysia. Sanctions imposed were largely redundant with restrictions already in place. Congressional Research Service 20 link to page 25 U.S. Sanctions on Russia  Exports related to space cooperation and commercial space launches; and  Export licensing for specific categories of national security-sensitive goods and technology, including exports related to civil aviation safety, commercial end-users civil end-uses, wholly owned U.S. and other foreign subsidiaries operating in Russia, and deemed export licenses for Russian nationals working in the United States.60 On November 6, 2018, the State Department informed Congress that it “could not certify that Russia met the required conditions” and intended “to proceed in accordance with the terms of the CBW Act, which directs the implementation of additional sanctions.”61 The Administration did not immediately impose a second round of CBW Act-related sanctions, but in December 2018 OFAC imposed sanctions on two GRU officers for the “attempted assassination” of Skripal and his daughter through the use of a lethal nerve agent.62 The Administration took its next steps to implement CBW Act-related sanctions in August 2019. On August 1, President Trump issued E.O. 13883 to require the Secretary of the Treasury to implement measures, “when necessary,” to oppose U.S. support for international financing and to prohibit access to U.S. bank loans.63 On August 2, Treasury issued a directive (the “CBW Act Directive”) specifying that the latter measures prohibited U.S. banks from “lending non-ruble denominated funds to the Russian sovereign” or participating “in the primary market for non-ruble denominated bonds issued by the Russian sovereign” (such restrictions were expanded to ruble-denominated funds in 2021; see “Poisoning of Alexei Navalny,” below).64 According to Treasury, U.S. banks are not prohibited from participating in the secondary market for Russian sovereign debt. Prohibitions do not apply to transactions with Russian state-owned enterprises. In addition, export licenses to Russian state-owned or state-funded enterprises for goods controlled for their dual-use chemical and biological applications became subject to a “presumption of denial” policy.65 Poisoning of Alexei Navalny On March 2, 2021, Secretary of State Antony Blinken determined that in August 2020, the Russian government used a chemical weapon against its own national, Russian opposition figure Alexei Navalny. This finding again triggered the CBW Act. The Department of State called the attack an “attempted assassination,” and the White House stated that the intelligence community 60 U.S. Department of State, “Determinations Regarding Use of Chemical Weapons by Russia Under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991,” 83 Federal Register 43723, August 27, 2018. 61 Reuters, “U.S. Intends More Sanctions On Russia Over Chemical Weapons: Spokeswoman,” November 6, 2018. 62 Although the attempted assassination was not cyber-related, OFAC used CRIEEA, Section 224 (undermining cybersecurity), to designate these officers as agents of the previously designated GRU. U.S. Department of the Treasury, “Treasury Targets Russian Operatives over Election Interference, World Anti-Doping Agency Hacking, and Other Malign Activities,” press release, December 19, 2018. 63 E.O. 13883 of August 1, 2019, “Administration of Proliferation Sanctions and Amendment of Executive Order 12851,” 84 Federal Register 38113. 64 Office of Foreign Assets Control, “Issuance of Russia-Related Directive Pursuant to Executive Order 13883 of August 1, 2019,” 84 Federal Register 48704, September 16, 2019. 65 U.S. Department of State, “Imposition of Additional Sanctions on Russia Under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991,”84 Federal Register 44671, August 26, 2019. Congressional Research Service 21 U.S. Sanctions on Russia assessed with “high confidence” that officers of the FSB were responsible for the attack. Russian authorities denied involvement.66 Secretary Blinken announced the imposition of the first round of sanctions but invoked national security waiver authority to allow for the continuation of  Foreign assistance;  Exports related to space cooperation and, until September 1, 2021, commercial space launches; and  Export licensing for specific categories of national security-sensitive goods and technology, including exports related to civil aviation safety, wholly owned U.S. and other foreign subsidiaries operating in Russia, and deemed export licenses.67 In addition, the Department of State added Russia to the International Trafficking in Arms Regulations list of countries subject to a policy of denial for exports of defense articles and services.68 The Department of State also imposed sanctions on the FSB, GRU, two GRU officers, and three research institutes for use of a chemical weapon in either the 2020 attack or the 2018 attack against Skripal (the FSB, GRU, and GRU officers were already subject to U.S. sanctions). These sanctions were imposed pursuant to E.O. 13382, targeting proliferators of weapons of mass destruction and their supporters.69 Simultaneously, the Treasury Department imposed sanctions on seven Russian government officials, including the FSB director and Russia’s prosecutor general, for Navalny’s poisoning and subsequent imprisonment. These sanctions were imposed pursuant to E.O. 13661 (issued in response to Russia’s invasion of Ukraine but targeting Russian government officials) and, in the case of the FSB director, also E.O. 13361. The sanctions were imposed in coordination with the EU, which imposed an initial round of sanctions in October 2020. On August 20, 2021, the State Department and the Treasury Department announced a second round of CBW Act sanctions and additional measures.70 These measures again included U.S. opposition to the provision of international loans or assistance to the Russian government, a prohibition against U.S. bank loans to the Russian government in non-ruble denominated funds, and a prohibition against U.S. bank participation in the primary market for non-ruble denominated sovereign bonds. Measures also included a “presumption of denial” policy on U.S. exports to Russia of nuclear, chemical, biological, and missile-related goods and technology, as well as a prohibition on the permanent importation of firearms and ammunition, as defined on the U.S. Munitions Import List, that are manufactured or located in Russia. 66 U.S. Department of State, “Imposing Sanctions on Russia for the Poisoning and Imprisonment of Aleksey Navalny,” March 2, 2021; and White House, “Press Briefing by Press Secretary Jen Psaki,” March 2, 2021. 67 U.S. Department of State, “Imposition of Additional Sanctions on Russia Under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991,” 86 Federal Register 24804, March 18, 2021. 68 U.S. Department of State, “International Traffic in Arms Regulations: Addition of Russia,” 86 Federal Register 14802, March 18, 2021. 69 Executive Order 13382 of June 28, 2005, “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters,” 70 Federal Register 38567. 70 U.S. Department of State, “Imposition of Additional Sanctions on Russia Under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991,” 86 Federal Register 50203, September 7, 2021. Congressional Research Service 22 U.S. Sanctions on Russia The Treasury Department or the State Department also imposed sanctions on nine Russian individuals (mostly FSB officers) and four Russian entities (two already subject to sanctions) involved in Navalny’s poisoning or Russia’s chemical weapons program. These sanctions were imposed pursuant to E.O. 13382 or E.O. 14024 (on Russian harmful foreign activities). Separately, under E.O. 14024, and an accompanying directive, the Biden Administration in April 2021 expanded the Trump Administration’s prohibition against U.S. financial institutions participating in the primary market for Russian sovereign bonds or lending to the Russian government to include ruble-denominated funds.71 Human Rights Abuses and Corruption Sanctions Authorities In December 2012, Congress passed and the President signed into law the Sergei Magnitsky Rule of Law Accountability Act of 2012 (hereinafter the Sergei Magnitsky Act).72 This legislation bears the name of Sergei Magnitsky, a Russian lawyer and auditor who died in prison in November 2009 after uncovering massive tax fraud that allegedly implicated government officials. The act entered into law as part of a broader piece of legislation related to U.S.-Russia trade relations (see text box entitled “Linking U.S.-Russia Trade to Human Rights,” below). The Sergei Magnitsky Act requires the President to impose sanctions on those he identifies as having been involved in the “criminal conspiracy” that Magnitsky uncovered and in his subsequent detention, abuse, and death.73 The act also requires the President to impose sanctions on those he finds have committed gross violations of internationally recognized human rights against individuals fighting to expose the illegal activity of Russian government officials or seeking to exercise or defend human rights and freedoms. Subsequently, in December 2016, the Global Magnitsky Human Rights Accountability Act (P.L. 114-328, Title XII, Subtitle F; 22 U.S.C. 2656 note) was enacted.74 This act authorizes the President to apply globally the human rights sanctions authorities aimed at the treatment of whistleblowers and human rights defenders that were originally set out in the Sergei Magnitsky Act. The Global Magnitsky Act also authorizes the President to impose sanctions against government officials and associates around the world responsible for acts of significant corruption. In December 2017, President Trump issued E.O. 13818 to implement the Global Magnitsky Act, in the process expanding the target for sanctions to include those who commit any “serious human rights abuse” around the world, not just gross human rights violations against whistleblowers and human rights defenders.75 71 Office of Foreign Assets Control, “Publication of Russian Harmful Foreign Activities Directive 1,” 86 Federal Register 35867, July 7, 2021. 72 The act was enacted as Title IV of the Russia and Moldova Jackson-Vanik Repeal and Sergei Magnitsky Rule of Law Accountability Act of 2012 (P.L. 112-208). “Jackson-Vanik” refers to provisions in the Trade Act of 1974 that conditioned U.S. trade with the Soviet Union on that country’s emigration policies (P.L. 93-618, §402; formerly 19 U.S.C. 2432) (see text box entitled “Linking U.S.-Russia Trade to Human Rights”). 73 Sergei Magnitsky Act, §404(a)(1); 22 U.S.C. 5811 note. 74 For more, see CRS In Focus IF10576, The Global Magnitsky Human Rights Accountability Act, by Michael A. Weber and Edward J. Collins-Chase. 75 Executive Order 13818 of December 20, 2017, “Blocking the Property of Persons Involved in Serious Human Rights Congressional Research Service 23 U.S. Sanctions on Russia SSIDES, as amended by CRIEEA in 2017, provides for sanctions on those responsible for “the commission of serious human rights abuses in any territory forcibly occupied or otherwise controlled” by the Russian government, as well as on Russian government officials and associates responsible for acts of significant corruption worldwide.76 In FY2008, Congress began including a requirement in annual State Department and Foreign Operations Appropriations Acts (referred to as Section 7031(c) authorities) that the Secretary of State shall deny entry into the United States of certain foreign officials involved in the corrupt extraction of natural resources. This provision gradually was broadened and now requires the denial of entry of foreign government officials and their immediate family members for whom there is credible information that the individual has been involved, “directly or indirectly, in significant corruption […] or a gross violation of human rights.”77 Related Actions As of January 2022, OFAC has designated 54 individuals and one entity pursuant to the Sergei Magnitsky Act. Forty designees are directly associated with the alleged crimes that Magnitsky uncovered or his subsequent ill-treatment and death. OFAC also has designated 11 individuals and one entity for human rights violations and killings in Russia’s Chechen Republic or for the 2004 killing of Paul Klebnikov, the American chief editor of the Russian edition of Forbes.78 Two designations target the suspected killers of former Russian spy Alexander Litvinenko in London in 2006.79 Another designation targets an overseer of prison abuse in Russia’s Karelia region. Under the Global Magnitsky Act, OFAC has designated at least 14 Russian nationals.80 Among the first round of designations was the son of Russia’s then-prosecutor general, who was cited for alleged involvement in high-level corruption.81 Subsequently, OFAC designated the head of Russia’s Chechen Republic and 11 related individuals and entities for serious human rights abuses. Abuse or Corruption,” 82 Federal Register 60839. E.O. 13818 must be extended annually to remain in force; the President extended it most recently on December 16, 2021. 76 P.L. 115-44, §228; 22 U.S.C. 8910. 77 Most recently, Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2020 (Division G, P.L. 116-94, Further Continuing Appropriations Act, 2020). Section 7031(c)(3) authorizes the Secretary of State to waive designating an individual if he determines “that the waiver would serve a compelling national interest or that the circumstances which caused the individual to be ineligible [to enter the United States] have changed sufficiently.” The act provides for private designations as well; designations are to be reported regularly to the Foreign Relations/Affairs, Appropriations, and Judiciary Committees. For more, see CRS In Focus IF10905, FY2020 Foreign Operations Appropriations: Targeting Foreign Corruption and Human Rights Violations, by Liana W. Rosen and Michael A. Weber. 78 On the killing of Paul Klebnikov, see Otto Pohl, “The Assassination of a Dream,” New York, November 2004; Richard Behar, “Open Letter to Russia’s Putin on Tenth Anniversary of Forbes’ Editor Paul Klebnikov’s Murder: Why Haven’t You Solved It?,” Forbes, July 16, 2014; and Bermet Talant, “American Journalist Paul Klebnikov’s Alleged Killer Arrested in Kyiv,” Kyiv Post, November 19, 2017. 79 On the killing of Alexander Litvinenko, see Alex Goldfarb with Marina Litvinenko, Death of a Dissident: The Poisoning of Alexander Litvinenko and the Return of the KGB (New York: Free Press, 2007); and Luke Harding, A Very Expensive Poison: The Assassination of Alexander Litvinenko and Putin’s War with the West (New York: Vintage Books, 2017). 80 In all, 146 individuals and 189 affiliated entities currently are designated pursuant to the Global Magnitsky Act. 81 Treasury also has designated under the Global Magnitsky Act a former Ukrainian special police force commander with dual Ukrainian-Russian citizenship; he was designated for violence against protestors in Ukraine. Congressional Research Service 24 U.S. Sanctions on Russia In 2018, President Trump cited SSIDES, as amended by CRIEEA, Section 228, to designate two individuals and one entity for committing serious human rights abuses in territories forcibly occupied or controlled by Russia. Under Section 7031(c) authorities, the State Department has publicly designated for human rights abuses at least nine Russian nationals: the head of Russia’s Chechen Republic, his spouse, and two children; another senior official from the Chechen Republic, his spouse, and another Chechen official; and two regional officials for their alleged involvement “in torture and/or cruel, inhuman, or degrading treatment or punishment” of Jehovah’s Witnesses.82 Linking U.S.-Russia Trade to Human Rights The Sergei Magnitsky Rule of Law Accountability Act of 2012 (Sergei Magnitsky Act; P.L. 112-208, Title IV; 22 U.S.C. 5811 note) continues a U.S. foreign policy tradition that links U.S. trade with Russia to concerns about human rights. The act is part of a broader piece of legislation granting permanent normal trade relations (PNTR) status to Russia. This legislation authorized the President to terminate the application to Russia of Title IV of the Trade Act of 1974 (P.L. 93-618; 19 U.S.C. 2101 et seq.), pursuant to which Russia was denied PNTR status. The Trade Act originally imposed restrictions on trade with Russia’s predecessor, the Soviet Union, due to its nonmarket economy and prohibitive emigration policies (the latter through Section 402, popularly cited as the Jackson-Vanik amendment). After the col apse of the Soviet Union, these trade restrictions formally continued to apply to Russia, even though the United States granted Russia conditional normal trade relations beginning in 1992. In 2012, Russia joined the World Trade Organization (WTO), with U.S. support. The United States subsequently had to grant Russia PNTR status or opt out of WTO “obligations, rules, and mechanisms” with respect to Russia (H.Rept. 112-632). Although the PNTR legislation enjoyed broad congressional support, some Members of Congress were reluctant to terminate the application to Russia of the Trade Act’s Jackson-Vanik amendment, which helped champion the cause of Soviet Jewish emigration in the 1970s, without replacing it with new human rights legislation. According to one of the original Senate sponsors of the Sergei Magnitsky Act, Senator Benjamin Cardin, pairing the Sergei Magnitsky Act with the PNTR legislation “allowed us to get this human rights tool enacted” while “[giving] us the best chance to get the PNTR bil done in the right form.” He elaborated, “today we close a chapter in the U.S. history on the advancing of human rights with the repeal ... of Jackson-Vanik. It served its purpose. Today, we open a new chapter in U.S. leadership for human rights with the Sergei Magnitsky Rule of Law Accountability Act” (Congressional Record, S7437, December 5, 2012). Section 241 “Oligarch” List and Related Sanctions CRIEEA, in Section 241, requires the Administration to submit a report to Congress that includes “an identification of any indices of corruption” among “the most significant senior foreign political figures and oligarchs in the Russian Federation, as determined by their closeness to the Russian regime and their net worth."” The Section 241 requirement neither authorizes nor requires the President to impose sanctions on individuals included in the report.

The Department of the Treasury The Treasury Department submitted this report in unclassified form with a classified annex in January 2018. The unclassified report drew on publicly available lists of political figures and wealthy Russians, without assessments of their closeness to the regime or "“indices of corruption."⁷⁰”83 According to the Department of the TreasuryTreasury Department, the classified annex contains an "“extremely thorough analysis"” of information pertaining, among other things, to "“links to corruption, and international business affiliations of the named Russian persons."⁷¹

”84 82 U.S. Department of State, “Public Designation Due to Involvement in Gross Violations of Human Rights of Vladimir Yermolayev and Stepan Tkach, Officials of the Investigative Committee in the Russian Federation,” September 10, 2019. 83 U.S. Department of the Treasury, “Treasury Releases CAATSA Reports, Including on Senior Foreign Political Figures and Oligarchs in the Russian Federation,” press release, January 29, 2018. 84 U.S. Department of the Treasury, “Treasury Information on CAATSA Report and Russian Sanctions,” press release, Congressional Research Service 25 link to page 23 U.S. Sanctions on Russia Many observers speculated that the list—or a more tailored version, possibly based on information from the classified annex—mightcould serve as the basis for new sanctions designations. In January 2018 testimony to the Senate Committee on Banking, Housing, and Urban Affairs, then-Secretary of the Treasury Steven Mnuchin indicated that "“we intend to now use that report and that intelligence to go forward with additional sanctions."⁷²

”85 On April 6, 2018, OFAC designated several politically connected Russian billionaires (whom the Department of the TreasuryTreasury Department referred to as oligarchs), companies owned or controlled by these individuals, and government officials. OFAC made these designations under Ukraine-related emergency authorities codified by CRIEEA. The Department of the Treasury, however, implied thatTreasury Department implied the designations were in the spirit of CRIEEA'’s broader authorities, as they were "“in response to worldwide malign activity"” and not just Russia'’s invasion of Ukraine.⁷³ The Department of the Treasury added that "86 The Treasury Department added, “Russian oligarchs and elites who profit from [a] corrupt system will no longer be insulated from the consequences of their government'’s destabilizing activities."

” In particular, the designation of Rusal, a leading global producer of aluminum, attracted international attention. The move marked the first time OFAC designated one of Russia's 20 largest ’s top companies. International attention also focused on the fact that designating Rusal could lead to the possible imposition of wide-ranging secondary sanctions, mandated by CRIEEA, on foreign individuals and entities that facilitate significant transactions on behalf of designees. Rusal's ’s designation made foreign banks and firms reluctant to engage in transactions with the firm.

The Trump Administration appeared to be responsive to international concerns regarding Rusal's ’s designation. In April 2018, the Administration provided a six-month wind-down period for transactions with Rusal that it repeatedly prolonged. In addition, Treasury officials indicated the United States would remove sanctions against the firm if Kremlin-connected billionaire Oleg Deripaska, who is subject to sanctions, divested and ceded control (since his control was the justification for Rusal'’s designation in the first place). In December 2018, the Department of the TreasuryTreasury Department announced that an agreement on eliminating Deripaska'’s control of Rusal'’s parent company had been reached and, accordingly, notified Congress it intended to terminate sanctions on Rusal and two related companies in 30 days.⁷⁴

87 The Russia Sanctions Review Act of 2017 (Part 1 of CRIEEA; 22 U.S.C. 9511) provides a means for Congress to block the President'’s action to terminate or waive certain sanctions on Russia if itCongress adopts a (presumably) veto-proof joint resolution of disapproval within 30 days of the President taking the action. In January 2019, the Senate and House each took up the matter. The House adopted H.J. Res. 30 to disapprove the delisting of Rusal by a vote of 362-53; the Senate, however, failed to invoke cloture for final consideration of its companion bill, S.J. Res. 2, by a vote of 57-42.

Use of a Chemical Weapon

February 1, 2018. 85 Testimony of Steven Mnuchin, in U.S. Congress, Senate Committee on Banking, Housing, and Urban Affairs, Hearing on Financial Stability Oversight Council Annual Report, 114th Cong., 2nd sess., January 30, 2018, transcript at http://www.cq.com/doc/congressionaltranscripts-5256410?17. 86 OFAC made the designations one month after the March 4, 2018, nerve agent attack against UK citizen and former Russian intelligence officer Sergei Skripal and his daughter in the United Kingdom (see “Use of a Chemical Weapon”) and one week after the Administration responded to that attack by expelling 60 Russian diplomats it said were intelligence operatives and closing Russia’s Consulate General in Seattle. U.S. Department of the Treasury, “Treasury Designates Russian Oligarchs, Officials, and Entities in Response to Worldwide Malign Activity,” press release, April 6, 2018. 87 U.S. Department of the Treasury, “OFAC Notifies Congress of Intent to Delist EN+, Rusal, and EuroSibEnergo,” press release, December 19, 2018; and RFE/RL, “Rusal Names New Chairman as Part of Deal to End U.S. Sanctions,” December 28, 2018. Congressional Research Service 26 U.S. Sanctions on Russia failed to invoke cloture for final consideration of its companion bill, S.J.Res. 2, by a vote of 57-42. Nord Stream 2: Energy Exports as a Coercive or Political Tool Three legislative authorities have established sanctions related to the use of Russian energy exports as a coercive or political tool. Two of these authorities have been used to target Russia’s Nord Stream 2 natural gas pipeline to Germany.88 Russian state-owned energy company Gazprom owns the Nord Stream 2 pipeline. Reportedly, about half the cost is financed by five European companies in agreements concluded prior to the enactment of these authorities. Construction of the Nord Stream 2 pipeline was initially suspended in December 2019, after Congress passed legislation establishing a new round of sanctions related to the pipeline. Construction resumed at the end of 2020 and reportedly was completed in September 2021. Additional steps, including certification by German authorities, are required before the pipeline will be able to transport gas.89 The first related authority is UFSA, Section 4(b)(3), which authorizes sanctions on Gazprom if the President determines Gazprom is withholding significant natural gas supplies from NATO member states or countries such as Ukraine, Georgia, and Moldova. No sanctions have been imposed under this authority. The second related authority is CRIEEA, Section 232, which authorizes (but does not require) sanctions on those who invest at least $1 million (or $5 million over 12 months) or provide goods, services, or support valued at the same amount for the construction of Russian energy export pipelines, including Nord Stream 2. On President Trump’s last full day in office, the Trump Administration imposed sanctions on Russian vessel Fortuna, which Gazprom was using to complete construction of Nord Stream 2, and its corporate owner, pursuant to Section 232. A third related authority is the Protecting Europe’s Energy Security Act of 2019, as amended (PEESA). PEESA was enacted on December 20, 2019, as part of the FY2020 National Defense Authorization Act (P.L. 116-92, Title LXXV). In January 2021, Congress amended PEESA to clarify and expand its pipeline-related sanctions (P.L. 116-283, §1242). In August 2021, President Biden issued E.O. 14039, establishing the means to implement certain sanctions provided for in PEESA.90 PEESA, as amended, establishes sanctions on foreign persons whom the President determines have sold, leased, provided, or facilitated the provision of vessels for the purpose of subsea pipe-laying activities related to the construction of Nord Stream 2 and TurkStream (a second new Russian gas export pipeline) or any successor pipeline.91 PEESA also targets those who provide underwriting services or insurance or who provide certain upgrades or installation services. Sanctions do not apply to nonbusiness entities of the EU, member states, or certain other non-EU governments. 88 For more, see CRS In Focus IF11138, Russia’s Nord Stream 2 Natural Gas Pipeline to Germany, by Paul Belkin, Michael Ratner, and Cory Welt. 89 America Hernandez, “3 Hurdles Still Facing the Nord Stream 2 Pipeline,” Politico, September 12, 2021. 90 Executive Order 14039 of August 20, 2021, “Blocking Property with Respect to Certain Russian Energy Export Pipelines,” 86 Federal Register 47205. 91 On TurkStream, see CRS In Focus IF11177, TurkStream: Russia’s Southern Pipeline to Europe, by Sarah E. Garding et al. Congressional Research Service 27 U.S. Sanctions on Russia PEESA provides for a 30-day wind-down period; exceptions for repairs, maintenance, environmental remediation, and safety; and a national security waiver. In addition, PEESA provides for the termination of sanctions if the President certifies to Congress “that appropriate safeguards have been put in place”  to minimize Russia’s ability to use the sanctioned pipeline project “as a tool of coercion and political leverage”; and  to ensure “that the project would not result in a decrease of more than 25 percent in the volume of Russian energy exports transiting through existing pipelines in other countries, particularly Ukraine, relative to the average monthly volume of Russian energy exports transiting through such pipelines in 2018.” In February 2021, the Biden Administration identified the previously designated Fortuna and its owner as also subject to sanctions under PEESA. In May 2021, the Administration designated an additional 13 vessels and four entities under PEESA; in August and November 2021, it designated another three vessels and three entities. In May 2021, the Administration waived the application of new sanctions on Nord Stream 2 AG, its chief executive officer, and corporate officers (Nord Stream 2 AG is a Swiss-based company Gazprom established to construct and operate the pipeline). Some Members of Congress have urged the Administration to impose additional sanctions to prevent the Nord Stream 2 pipeline from becoming operational. In addition to these legislative provisions, E.O. 14024 provides for sanctions on Russian individuals and entities responsible for, among other harmful activities, “cutting or disrupting gas or energy supplies to Europe, the Caucasus, or Asia.”92 Other Sanctions Programs Other Sanctions Programs

The United States imposes economic sanctions on Russian individuals and entities in response to a variety ofvarious other objectionable activities. These activities include weapons proliferation, trade with North Korea in violation of U.N. Security Council requirements, support for the Syrian and Venezuelan governments, transnational crime, and international terrorism.

Weapons Proliferation

Several laws require the President to impose sanctions on those hethe President determines have engaged in trade in weapons of mass destruction or advanced conventional weapons.⁸⁷ 93 Restrictions cover a range of activities but generallyand can include a one- to two-year cutoff of procurement contracts with the U.S. government and restrictions on import and export licensing. Restrictions also may include a denial of U.S. foreign aid, sales of defense articles and defense services subject to U.S. export control for national security and foreign policy purposes (U.S. Munitions List items), and export licenses for dual-use goods and services (Commerce Control List).⁸⁸

Pursuant to the Iran, North Korea, and Syria Nonproliferation Act, as amended (INKSNA), Russian state-owned arms exporter Rosoboronexport and seven other Russian defense 94 92 Executive Order 14024 of April 15, 2021, “Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation,” 86 Federal Register 20249. 93 See CRS Report RL31502, Nuclear, Biological, Chemical, and Missile Proliferation Sanctions: Selected Current Law, by Dianne E. Rennack. 94 Defense articles and defense services subject to U.S. export controls for national security and foreign policy purposes are identified on the U.S. Munitions List, as established in Section 38 of the Arms Export Control Act (22 U.S.C. 2778). Dual-use goods and services similarly subject to export controls are identified on the Commerce Control List, 15 Congressional Research Service 28 link to page 37 U.S. Sanctions on Russia Pursuant to the Iran, North Korea, and Syria Nonproliferation Act, as amended (INKSNA; (P.L. 106-178; 50 U.S.C. 1701 note), Russian state-owned arms exporter Rosoboronexport and at least nine other Russian entities currently are denied most U.S. government procurement contracts, export licenses, and trade in U.S. Munitions List-controlled goods and services. Weapons proliferation sanctions against Rosoboronexport are in addition to Ukraine-related sectoral sanctions imposed on the agency in December 2015 and its designation in April 2018 as an SDN for providing support to the Syrian government.⁸⁹95 Restrictions against entering into government contracts and other transactions with Rosoboronexport have been stated in annual Defense appropriations acts since 2013 (see "“Restrictions on U.S. Government Funding,",” below).96 BIS periodically has imposed Weapons Proliferation Sanctions on Russia: restrictions for suspected violations Historical Background of the EAR with respect to exports The United States has imposed various proliferation-related to Russia for military and other below).

The prohibitions against transactions with Rosoboronexport do CFR Part 774 Supplement 1, pursuant to authorities in the Export Control Act of 2018 (P.L. 115-232, Title XVII, Part I) to the extent it continues regulations issued under the Export Administration Act of 1979 (P.L. 96-72; 50 U.S.C. 4601 et seq.) (see, in particular, §1758(g)(2) of the 2018 act). The Commerce Control List, under the Export Control Act of 2018 (§1759), is subject to review not later than 270 days after the date of enactment. The act was signed into law on August 13, 2018. 95 Two other Russian defense firms, the Instrument Design Bureau (precision-guided weapons) and NPO Mashinostroyenia (rockets and missiles), also have been subject to recurring U.S. proliferation sanctions since 2014, in addition to being designated pursuant to Ukraine-related executive orders. 96 The prohibitions against transactions with Rosoboronexport did not apply to contracts related to the maintenance or repair of Mi-17 helicopters purchased by the United States "“for the purpose of providing assistance to the security forces of Afghanistan, as well as for the purpose of combating terrorism and violent extremism globally."” They also do did not apply to procurement related to the purchase or maintenance of optical sensors that "“improve the U.S. ability to monitor and verify Russia'’s Open Skies Treaty compliance.” U.S. Department of State, “Imposition of Nonproliferation Measures Against Rosoboronexport, Including a Ban on U.S. Government Procurement,” 83 Federal Register 21333, May 9, 2018. 97 In 2012, for example, the U.S. Department of Justice made public an indictment of eleven U.S. and Russian companies and individuals for the illegal export of “high-tech microelectronics from the United States to Russian military and intelligence agencies.” Concurrently, the Department of Commerce’s BIS imposed restrictions on about 165 individuals and entities (Russians and others) for suspected involvement in procurement and delivery of items to Russia for military-related and other governmental or related end uses in violation of export and arms trade regulations. U.S. Department of Justice, “Russian Agent and 10 Other Members of Procurement Network for Russian Military and Intelligence, Operating in the U.S. and Russia, Indicted,” press release, October 9, 2012; and BIS, “Addition of Certain Congressional Research Service 29 U.S. Sanctions on Russia s Open Skies Treaty compliance."⁹⁰

United States withdrew from the treaty in August 2019.98 North Korea Sanctions Violations

The U.N. Security Council, beginning in 2006, has required its member states to curtail a range of diplomatic, finance, trade, and exchange relations with North Korea. The Security Council took action in response to North Korea'’s withdrawal from the Treaty on Non-Proliferation of Nuclear Weapons, testing of nuclear weapons, and efforts to develop missile delivery systems. Security Council resolutions also have drawn attention to North Korea'’s abuse of diplomatic privileges and immunities, money laundering, bulk cash smuggling, disruption of regional stability, and disregard for the human rights conditions of its civilian population.⁹⁴

99 To meet the United States'’ U.N. obligations, and to implement requirements enacted in the North Korea Sanctions and Policy Enhancement Act of 2016 (P.L. 114-122; 22 U.S.C. 9201 et seq.), as amended by the Korean Interdiction and Modernization of Sanctions Act (CAATSA, Title III), the President has issued a series of executive orders to block assets, transactions, and travel of designated North Korean individuals and entities. These sanctions also apply to other foreign individuals and entities that engage in trade or support North Korean designees.⁹⁵

The Trump Administration has designated at least 22100 Treasury currently designates more than 20 Russia-related individuals, entities, and vessels for evading sanctions restricting trade and financial transactions with North Korea. Designations include the following:

• in June and August 2017, a Russian oil company and its subsidiary  A Russian oil company and its subsidiary (both delisted in 2020 after they were deemed to be in compliance), three Russian individuals, and two Singapore-based companies those individuals control for trade in petroleum with North Korea, under E.O. 13722 of March 15, 2016 (designated in June and August 2017)  TwoKorea, under EO 13722 (March 2016);
• in June 2017, two Russian entities and two related individuals for providing supplies and procuring metals to a North Korean company designated in 2009 for its weapons of mass destruction programs, under EO 13382 (June 2005);
• in August 2018, aE.O. 13382 of June 28, 2005 (June 2017)  A Russian bank for "“facilitating a significant transaction on behalf of an individual designated for weapons of mass destruction-related activities," under EO 13810 (September 2017);⁹⁶
• in August 2018, two Russian shipping companies and six vessels for involvement "” under E.O. 13810 of September 20, 2017 (August 2018)101 Persons to the Entity List,” 77 Federal Register 61249, October 9, 2012. 98 BIS, “Addition of Certain Persons to the Entity List,” 82 Federal Register 60304, December 20, 2017. For more, see CRS In Focus IF11051, U.S. Withdrawal from the INF Treaty: What’s Next?, by Amy F. Woolf. 99 See CRS Report R41438, North Korea: Legislative Basis for U.S. Economic Sanctions, by Dianne E. Rennack. 100 The E.O.s referenced in this section are E.O. 13382 of June 28, 2005, “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters,” 70 Federal Register 38567; E.O. 13722 of March 15, 2016, “Blocking Property of the Government of North Korea and the Workers’ Party of Korea, and Prohibiting Certain Transactions With Respect to North Korea,” 81 Federal Register 14943; and E.O. 13810 of September 20, 2017, “Imposing Additional Sanctions With Respect to North Korea,” 82 Federal Register 44705. Other North Korea-related E.O.s are E.O. 13466 (June 26, 2008), E.O. 13551 (August 30, 2010), E.O. 13570 (April 18, 2011), and E.O. 13687 (January 2, 2015). 101 According to the Treasury Department, the bank had a commercial relationship with North Korean entities since at least 2009. U.S. Department of the Treasury, “Treasury Targets Russian Bank and Other Facilitators of North Korean United Nations Security Council Violations,” press release, August 3, 2018. Congressional Research Service 30 link to page 32 U.S. Sanctions on Russia  Two Russian shipping companies and six vessels for involvement “in the ship-to- in the ship-to-ship transfer of refined petroleum products with North Korea-flagged vessels, an activity expressly prohibited by the U.N. Security Council," under EO 13810;⁹⁷
• in September 2018, a” under E.O. 13810 (August 2018)102  A Russia-based front company for a China-based information technology company that "in reality ... “is managed and controlled by North Koreans"” and facilitates the exportation of information technology workers from North Korea, under EO 13722 and EO 13810;⁹⁸ and
• in June 2019, aE.O. 13722 and E.O. 13810 (September 2018)103  A Russian institution for helping North Korea evade sanctions through the provision of financial services to a subsidiary of North Korea'’s primary foreign exchange bank and a zinc export company, under EO 13382.

E.O. 13382 (June 2019)  A Russian construction company for seeking and receiving work permits for workers from North Korea, under E.O. 13722 (November 2020)  A Russian entity and a related individual for weapons proliferation-related transactions, under E.O. 13382 (January 2022) Syria-Related Sanctions Syria-Related Sanctions

In a series of executive orders dating back to 2004, the President has sought to block trade and transactions with the government of Syria and its supporters. The U.S. government has imposed these sanctions in response to Syria'’s past occupation of Lebanon, support of international terrorism, pursuit of weapons of mass destruction and the means to deliver them, undermining of international efforts to stabilize Iraq, and escalating violence against its own people.⁹⁹

104 In April 2018, OFAC designated Russia'’s state-owned arms exporter Rosoboronexport and an associated bank pursuant to EOE.O. 13582 (August 2011) for providing material support and services to the government of Syria.¹⁰⁰105 Previously, during the Obama Administration, OFAC designated two other banks, which have since had their licenses revoked, and 12 related individuals pursuant to EO 13582 (in May 2014, November 2015, and December 2016).

E.O. 13582. In November 2018, OFAC designated under EOE.O. 13582 one Russian individual and three Russia-based entities for providing material support and services to the government of Syria. Treasury said these designees were part of "“a complex scheme Iran and Russia have used to bolster the Assad regime and generate funds for Iranian malign activity."” This scheme involved moving oil from Iran to Syria and funneling funds to the Islamic Revolutionary Guard Corps-Qods Force, its proxies, and Hamas and Hezbollah.106 102 U.S. Department of the Treasury, “Treasury Targets Russian Shipping Companies for Violations of North Korea-Related United Nations Security Council Resolutions,” press release, August 21, 2018. 103 U.S. Department of the Treasury, “Treasury Targets North Korea-Controlled Information Technology Companies in China and Russia,” press release, September 13, 2018. 104 The E.O. referenced in this section is E.O. 13582 of August 17, 2011, “Blocking Property of the Government of Syria and Prohibiting Certain Transactions with Respect to Syria,” 76 Federal Register 52209. The initial declaration of a national emergency relating to Syria is stated in E.O. 13338 of May 11, 2004, “Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria,” 69 Federal Register 26751. 105 Before Rosoboronexport was designated as an SDN in April 2018, SSI sectoral sanctions applied to it as a subsidiary of the Russian defense conglomerate Rostec. Other sanctions relating to weapons proliferation also applied (see “Weapons Proliferation”). 106 The Islamic Revolutionary Guard Corps-Qods Force, Hamas, and Hezbollah are each subject to U.S. sanctions as foreign terrorist organizations (FTO), specially designated global terrorists (SDGT), and for their activities in the Middle East. One of the designated entities also was designated for Iran-related activities and as an SDGT. Another Congressional Research Service 31 U.S. Sanctions on Russia In September 2019, OFAC designated one entity under E.O. 13582 and associated individuals and vessels under the Ukraine-related E.O. 13685 for providing material support and services to the government of Syria and for evading Ukraine-related sanctions. Treasury said the entity was serving as a front company for a sanctioned entity as part of a “scheme to facilitate the [illicit transfer] of jet fuel to Russian forces operating in Syria.”107 Venezuela-Related Sanctions In March 2019, OFAC designated a bank that is jointly owned by Russian and Venezuelan state-owned companies under E.O. 13850 for providing support to Venezuela’s state-owned oil company, Petróleos de Venezuela, S.A. (PdVSA).108 The Administration designated PdVSA in January 2019 to curb the availability of resources to the regime of Nicolás Maduro. In February and March 2020, OFAC designated two subsidiaries of Russian state-owned oil company Rosneft and one corporate officer for operating in Venezuela’s oil sector under E.O. 13850. In January 2021, Treasury designated under E.O. 13850 two Russian-flagged vessels and their registered owners, among others, for attempting to evade U.S. sanctions. Transnational Crime Russian nationals are subject to sanctions for activities related to transnational crime.109 OFAC currently designates at least 15 Russian individuals and six entities for their roles in transnational criminal organizations (TCOs). In December 2017, OFAC designated as a TCO the “Thieves-in-Law,” which it characterized as “a Eurasian crime syndicate that has been linked to a long list of illicit activity across the globe.”110 OFAC designated 10 individuals (Russian nationals and others) and two entities as TCOs for their relation to the Thieves-in-Law; these designees include several individuals OFAC previously designated, during the Obama Administration, as part of a related TCO, the Brothers’ Circle.111 When OFAC designated the Thieves-in-Law, it delisted the Brothers’ Circle and some related individuals and entities. was designated previously for Iran-related activities and as an SDGT. U.S. Department of the Treasury, “Treasury Designates Illicit Russia-Iran Oil Network Supporting the Assad Regime, Hizballah, and HAMAS,” press release, November 20, 2018. 107 U.S. Department of the Treasury, “Treasury Targets Sanctions Evasion Scheme Facilitating Jet Fuel Shipments to Russian Military Forces in Syria,” press release, September 26, 2019. 108 E.O. 13850 of November 1, 2018, “Blocking Property of Additional Persons Contributing to the Situation in Venezuela,” 83 Federal Register 55243. The initial declaration of a national emergency relating to Venezuela is stated in E.O. 13692 of March 8, 2015, “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela,” 80 Federal Register 12747. 109 E.O. 13581 of July 24, 2011, “Blocking Property of Transnational Criminal Organizations,” 76 Federal Register 44757. Although the E.O. does not explicitly address denial of entry into the United States of transnational crime (TCO) designees, the Secretary of Homeland Security, Secretary of State, and Attorney General could draw on authorities stated in the Immigration and Nationality Act (at 8 U.S.C. 1189) to deny entry. 110 U.S. Department of the Treasury, “Treasury Targets the ‘Thieves-in-Law’ Eurasian Transnational Criminal Organization,” press release, December 22, 2017. 111 The Obama Administration designated the Brothers’ Circle as one of four transnational criminal organizations under E.O. 13581 of July 24, 2011 (the other three were the Italian Camorra, Japanese Yakuza, and Mexico-based Loz Zetas). The Administration described the Brothers’ Circle as “a criminal group composed of leaders and senior members of several Eurasian criminal groups that ... serves as a coordinating body for several criminal networks, mediates disputes between the individual criminal networks, and directs member criminal activity globally.” It indicated that many Brothers’ Circle members “share a common ideology based on the ‘thief-in-law’ tradition.” In all, the Obama Congressional Research Service 32 U.S. Sanctions on Russia Terrorism Russian nationalsproxies, and Hamas and Hezbollah.¹⁰¹

Venezuela-Related Sanctions

Energy Export Pipelines

The Trump Administration has not used Section 232 to oppose the construction of Nord Stream 2. In October 2017, the Administration published guidance noting that Section 232 sanctions would not apply to projects for which contracts were signed prior to August 2, 2017, the date of CRIEEA's enactment.¹⁰⁵ Gazprom signed agreements with five European companies to partially finance the construction of Nord Stream 2 in April 2017. Section 232 does not provide for sanctions on financing specifically, although it does provide for sanctions on the provision of services and support.

Transnational Crime

Terrorism

Russian individuals and entities are subject to sanctions related to international terrorism.¹¹⁵ are subject to sanctions related to international terrorism.112 OFAC has designated at least 2two entities and 12 affiliated individuals, in Russia or as fighters abroad, as Specially Designated Global Terrorists (SDGTs). The Caucasus Emirate, a terrorist and insurgent group in Russia'’s North Caucasus region, was established in 2007; OFAC listed its founder, Doku Umarov, as an SDGT in 2010 (he was killed in 2013).¹¹⁶113 OFAC designated the Caucasus Emirate itself in May 2011. In 2015, the Islamic State recognized as its local affiliate the Caucasus Province (Vilayet), which reportedly was established by insurgents previously affiliated with the Caucasus Emirate. OFAC designated the Caucasus Province as an SDGT in September 2015.

Restrictions on U.S. Government Funding

As in past years, FY2020FY2021 appropriations restrict assistance to the Russian government. The Department of Defense Appropriations Act, 2020 (2021 (P.L. 116-93260, Division AC), prohibits the use of defense funding to make a loan or loan guarantee to Rosoboronexport or any of its subsidiaries (§8101). The Energy and Water Development and Related Agencies Appropriations Act, 2020 (P.L. 116-94, Division C), prohibits funds to Russia from the Defense Nuclear Nonproliferation account (§305(a)).¹¹⁷(§8102).114 The Department of State, Foreign Operations, and Related Programs Appropriations Act, 2020 (2021 (P.L. 116-94260, Division GK), requires country notification procedures to be invoked for foreign aid to Russia (§7015(f)). This act also prohibits funds from being made available to Russia'Russia’s central government (§7047(a)), a restriction in place since FY2015.

The State Department's 2019 Trafficking in Persons Report identifies Pursuant to the Trafficking Victims Protection Act, the State Department every year since 2013 has identified Russia as a Tier 3 nation that fails to meet minimum standards for the elimination of human trafficking and is not making significant efforts to do so. As a result, the President does not provide non-humanitarian, non-trade-related assistance to the Russian government and denies U.S. support for multilateral development loans or other funds to the Russian government. For FY2022, however, the President determined it is in the U.S. national interest to waive restrictions on funds for Russia’s participation in educational and cultural exchange programs as described in Section 110(d)(1)(A)(ii) of the act.115 Administration designated a related 23 individuals (Russian nationals and others) and 7 entities pursuant to E.O. 13581. U.S. Department of the Treasury, “Fact Sheet: New Executive Order Targets Significant Transnational Criminal Organizations,” July 25, 2011; and U.S. Department of the Treasury, “Treasury Designates Key Members of the Brothers’ Circle Criminal Organization,” press release, December 20, 2012. 112 E.O. 13224 of September 23, 2001, “Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism,” 66 Federal Register 49079; E.O. 13268 of July 2, 2002, “Termination of Emergency With Respect to the Taliban and Amendment of Executive Order 13224 of September 23, 2001,” 67 Federal Register 44751; and E.O. 13372 of February 16, 2005, “Clarification of Certain Executive Orders Blocking Property and Prohibiting Certain Transactions,” 70 Federal Register 8499. 113 OFAC also designated Umarov’s successor as a Specially Designated Global Terrorist less than a month before his death in 2015. After a designee dies, an SDN remains designated so that his or her estate remains subject to blocking. Descendants may appeal to OFAC to have assets released. 114 The restriction in Defense appropriations has been in place since FY2013. 115 The waiver justification notes the value of including “Russian teachers, academics, doctors, nurses, researchers, and legal professionals, ... individuals employed at public institutions, reform-oriented government officials at the regional or municipal level, and teachers of minority languages and cultures” in educational and cultural exchanges. Presidential Determination No. 2022-06, “Presidential Determination with Respect to the Efforts of Foreign Governments Regarding Trafficking in Persons,” White House publication, December 21, 2021. For additional information on the trafficking in persons report and associated aid restrictions, see CRS Report R44953, The State Department’s Trafficking in Persons Report: Scope, Aid Restrictions, and Methodology, by Michael A. Weber, Katarina C. O'Regan, and Liana W. Rosen. Congressional Research Service 33 U.S. Sanctions on Russia Underof human trafficking. The designation requires limits on aid and U.S. support in international financial institutions.¹¹⁸

In 2018, under the International Religious Freedom Act of 1998, as amended (P.L. 105-292, 22 U.S.C. 6401 et seq.), since 2018 Russia has been included6401 et seq.), Secretary of State Pompeo included Russia for the first time on the Special Watch List identifying "“governments that have engaged in or tolerated severe violations of religious freedom."¹¹⁹”116 The Special Watch List was established in 2016 to publicly name foreign governments whose treatment of religious freedoms has deteriorated over the past year. Naming to the Special Watch List serves as a warning that the United States could be considering designating the foreign nation as a Country of Particular Concern (CPC) in the comingcountries that have severe religious freedom violations but whose treatment of religious freedoms was judged by the President to not meet the criteria for designation as a Country of Particular Concern (CPC). A Special Watch List designation may serve as a warning that the United States could designate the foreign nation as a CPC in a subsequent year. If Russia were to be designated a CPC, it would become subject to potential diplomatic and economic sanctions that could range from private demarches to prohibitions on export licensing, procurement contracts, and transactions through U.S. financial institutions.117 institutions.¹²⁰ In 2019, the U.S. Commission on International Religious Freedom, a bipartisan federal government commission, recommended that Russia be designated as a CPC.¹²¹

Russian Countersanctions

Russian Countersanctions The Russian government has responded to U.S. and other sanctions by imposing a variety of retaliatory measures, also known as countersanctions. The day the Senate passed the Sergei Magnitsky Act in December 2012, the Russian government announced new restrictions on imported beef, pork, and poultry that, within a few months, led to a major decline in U.S. meat imports to Russia.¹²²118 Several days after President Obama signed the actSergei Magnitsky Act into law, the Russian parliament voted to ban U.S. adoptions of Russian children.¹²³119 It also introduced a visa ban against U.S. citizens whom Russia characterized as being involved in human rights violations or crimes against and persecution of Russian citizens. The day after OFAC issued its first designations under the Sergei Magnitsky Act in April 2013, the Russian government issued a list of U.S. citizens prohibited from entering Russia.¹²⁴

120 Russia also imposed countersanctions in response to U.S. and EU sanctions related to Russia's ’s invasion of Ukraine. These measures included additional travel prohibitions and a ban on the import of agricultural products from countries that had imposed sanctions on Russia.

U.S. and EU Coordination on Sanctions

After the United States’ imposition of new designations of Russian government officials and politically connected billionaires and their holdings in April 2018, President Putin signed into law an act authorizing, but not requiring, restrictions related to trade with the United States and other unfriendly states, as well as foreign access to Russian public procurement and privatization.121 116 U.S. Department of State, “Briefing on Religious Freedom Designations,” December 11, 2018. 117 Actions against Countries of Particular Concern are subject to potential exceptions and waivers. For additional information, see CRS In Focus IF10803, Global Human Rights: International Religious Freedom Policy, by Michael A. Weber. 118 Ellen Barry, “Russia Announces Barriers on Imports of U.S. Meat,” New York Times, December 8, 2012; and Dina Gusovsky, “Russia’s U.S. Meat Ban: What’s the Beef?” CNBC, February 20, 2013. 119 Charles Clover, “Russia Bans Adoptions by U.S. Citizens,” Financial Times, December 21, 2012. This Russian ban on U.S. adoptions, taken in response to the Sergei Magnitsky Act, emerged as an issue in the U.S. Special Prosecutor’s investigation of possible Russian interference in the 2016 U.S. presidential election. See, for example, Jo Becker, Matt Apuzzo, and Adam Goldman, “Trump Team Met with Lawyer Linked to Kremlin During Campaign,” New York Times, July 8, 2017. 120 U.S. Department of State, “Release of Magnitsky List,” April 12, 2013; and VOA News, “Russia Bans 18 Citizens,” April 13, 2013. 121 Konstantin Kroll, Mikhail Usubyan, and Harry Clark, “Further Update—Russian Counter-Sanctions Measures and New U.S. Sanctions Against Russia,” Orrick, June 18, 2018; and Reuters, “Factbox: Russia’s List of U.S. Imports That Could Be Banned,” April 13, 2018. Congressional Research Service 34 U.S. Sanctions on Russia In response to Biden Administration sanctions and diplomatic expulsions in April 2021, Russian authorities took reciprocal actions and said Russia would “limit and suspend the activities” of U.S. nongovernmental organizations and foundations that “directly interfere in [Russian] political life.” (Russian nationals already are prohibited from working with or receiving money from several U.S. nongovernmental organizations, and other organizations have been required to publicly label themselves as “foreign agents” or cease operations.) Russian officials said they would hold in reserve “painful” measures against U.S. businesses.122 Since 2017, the Russian government has responded to the United States’ expulsion of Russian officials from diplomatic missions in the United States and orders to close some diplomatic offices with a series of tit-for-tat diplomatic reductions and closures.123 In 2021, Russian authorities prohibited the employment of Russian nationals in the U.S. diplomatic mission. As a result, U.S. embassy and consular operations in Russia were reduced substantially.124 U.S. and EU Coordination on Sanctions Like the United States, the EU has imposed sanctions—or restrictive measures in EU parlance—in response to Russia’s 2014 invasion of Ukraine. The EU also has imposed sanctions in response to Russia’s use of chemical weapons, human rights violations, and malicious cyber activity. Authorized sanctions include travel bans and asset freezes. The EU has imposed these sanctions largely in cooperation with the United States. EU sanctions are similar, but not identical, to U.S. sanctions. Imposing EU sanctions requires the unanimous agreement of all EU member states. Most EU sanctions are imposed for a defined period of time (usually six months or a year) to incentivize change and provide the EU with flexibility to adjust the sanctions as warranted. Unanimity among EU member states also is required to renew (i.e., extend) EU sanctions.

Comparing U.S. and EU Cooperation on Ukraine-Related Sanctions

Since Russia'’s invasion of Ukraine in 2014, the United States and the EU have pursued largely similar policies—including related to sanctions—aimed at restoring Ukraine'’s territorial integrity and supporting domestic politicalUkraine’s governance reforms. Observers have viewed U.S.-EU cooperation in imposing sanctions on Russia and coordination on other political and diplomatic responses to Russia'Russia’s invasion as a high point in transatlantic relations and as a means to prevent Russia from driving a wedge between the United States and Europe.

The EU has tied lifting sanctions on Russia to the full implementation of the Minsk peace agreements for Ukraine and asserts that it is committed to maintaining sanctions until this goal is achieved. At the same time, questions persist in some EU countries about the sanctions' effectiveness, especially amid concerns that sanctions could be hindering EU relations with Russia on other global priorities and harming European business interests. The EU sanctions (and Russian countersanctions) have come with financial costs for certain industries in some EU member states, including Germany, Finland, and the Baltic states, although the overall impact on EU trade appears to be limited.¹³² Some The EU has tied lifting sanctions on Russia to the full implementation of the Minsk agreements that provide a framework for conflict resolution in eastern Ukraine and asserts that it is committed to maintaining sanctions until this goal is achieved. At the same time, questions persist in some EU countries about the sanctions’ effectiveness, especially amid concerns that sanctions could be hindering EU relations with Russia on other global priorities and harming certain European business interests, although the overall impact on EU trade appears to be limited. Some 122 Robyn Dixon, “Russia to Expel 10 U.S. Diplomats in Response to Biden Administration Sanctions,” Washington Post, April 16, 2021; and Henry Foy, “Russia Counters U.S. Sanctions with Diplomat Expulsions,” Financial Times, April 16, 2021. 123 For more, see CRS Report R46761, Russia: Foreign Policy and U.S. Relations, by Andrew S. Bowen and Cory Welt. 124 Robbie Gramer, “Under Putin’s Rules, U.S. Mission in Russia Left with Skeleton Crew,” Foreign Policy, July 29, 2021; and Joel Gehrke, “State Department Struggles to Keep Moscow Embassy Open Due to Staffing Feud with Russia,” Washington Examiner, October 27, 2021. Congressional Research Service 35 U.S. Sanctions on Russia European officials have periodically floated ideas about restructuring the sanctions. Others firmly reject suggestions to relax or recalibrate EU sanctions and have urged the Trump Administration to uphold U.S. sanctions on Russia.

U.S. and EU Ukraine-Related Sanctions Compared

. EU sanctions in response to Russia'’s invasion of Ukraine consist of three measures:

•  Restrictive measures on individuals and entities in Russia and Ukraine believed to be involved in the annexation of Crimea and destabilization of eastern Ukraine. Designees are subject to asset freezes and, for individuals, visa bans. As of January 20202022, the EU has designated 170185 individuals and 4448 entities (Council Decision 2014/145/CFSP, March 17, 2014).
•  Economic sanctions targeting Russia'’s finance, defense, and energy sectors (sectoral (sectoral sanctions). The EU requires its member states to impose lending and investment restrictions on five major state-controlled Russian banks, three defense firms, and three energy companies, as well as their subsidiaries outside the EU. The sanctions also ban the import and export of arms; the sale of dual-use goods and technology to Russian military end users and nine mixed companies; and sales of equipment, technology, and services for oil-development projects related to deepwater, Arctic offshore, and shale exploration (Council Decision 2014/512/CFSP, July 31, 2014).
•  Restrictions on economic relations with Ukraine'sUkraine’s occupied Crimea region. The EU has banned EU individuals and EU-based companies from importing goods, exporting certain goods and technologies, and providing tourism services to Ukraine'’s Crimea region. The EU also has restricted trade and investment in certain economic sectors and infrastructure projects (Council Decision 2014/386/CFSP, June 23, 2014).

In addition, in response to the political upheaval in Ukraine in early 2014 and in an effort to bolster Ukraine's domestic reforms In addition, in 2014, the EU imposed restrictive measures on individuals identified as responsible for the misappropriation of Ukrainian state funds or for the abuse of office causing a loss of Ukrainian public funds. The EU hoped to prevent the transfer of such funds outside of Ukraine and to facilitate their recovery. As of January 20202022, the EU has frozen assets of and imposed visa bans on 128 former Ukrainian officials (originally 22), including ex-Ukrainian president Viktor Yanukovych (Council Decision 2014/119/CFSP, March 5, 2014).

Sanctions Targeting Individuals and Entities

The U.S. and EU Ukraine has an extensive sanctions regime against Russia, which has responded with its own wide-ranging sanctions on Ukrainian individuals and entities. Despite U.S. and EU coordination on sanctions, their lists of designated individuals and entities are not identical. Various legal and political reasons account for some of the differences in the U.S. and EU designations. The EU has imposed sanctions on more individuals and entities directly related to the fighting in Ukraine—military officials, insurgents, and battalions—than has the United States. The United States has specifically designated more companies operating in Crimea and entities affiliated with other designated individuals and entities, whereas the EU provides for blanket restrictions on Crimea-related activities and against affiliated individuals and entities. The EU is unable to impose restrictive measures on some individuals who hold dual citizenship with EU countries.

Congressional Research Service 36 link to page 60 U.S. Sanctions on Russia Since 2014, several individuals have been removed from the EU sanctions list. Unlike the United States, which requires a decedent'’s survivors to petition for removal, the EU removes individuals from its sanctions list due to death. In addition, someseveral designees have successfully petitioned for their removal.

Sectoral Sanctions

EU and U.S. restrictions against lending and/or investments with entities in specific sectors mostly overlap and target a handful of key companies and their subsidiaries in the financial, defense, and energy sectors, including exports and services related to deepwater, Arctic offshore, or shale oil projects in Russia (see Table CD-1). -1).

The manners in which the United States and the EU employ this measure differ somewhat and have changed over time. have changed over time. As of January 2020, the United States specifically identifies 13 Russian companies and 276 of their subsidiaries and affiliates as subject to sectoral sanctions. The EU, for its part, identifies 11 entities (and majority-owned subsidiaries outside the EU) as subject to sectoral sanctions. The United States has explicitly identified several companies, including Gazprom, with which sales of equipment, technology, and services for certain oil projects are prohibited; by contrast, the EU has not named specific companies to which these prohibitions apply. In addition, the EU does not impose sanctions on such oil projects worldwide, as does the United States does.

. EU and U.S. policies are comparable in restricting most arms trade with and dual-use exports to Russia, but the EU applied arms-trade sanctions to future contracts only. The EU decision to allow existing arms sales and service contracts with Russia to continue was largely at the insistence of France (which had an existing contract to sell two Mistral helicopter carriers to Russia) and some Central European countries that rely on Russian companies to service their Soviet-era weapons systems. AnalystsReports suggest, however, that the arms-trade sanctions—and ongoing concern about Russia'’s actions in Ukraine and Russia'’s military resurgence—prompted EU members to reevaluate some existing weapons system sales and licenses. Although not required to do so under the terms of the EU sanctions, FranceFrance, for example, canceled thea contract with Russia for thetwo Mistral helicopter carriers. Germany also canceled a contract to supply Russia with a $155 million combat simulation center.¹³³ Central and Eastern European countries have been advancing plans to phase out Russian-origin military equipment and replace it with more modern U.S. and European equipment.¹³⁴

125 The EU and the United States also addressed the issue of existing sales and service contracts on energy development projects differently. The EU allowed for the continuation of existing contracts and agreements, in certain cases with authorization at the national level. The United States generally prohibited, other than a brief wind-down period, the continuation of existing contracts and agreements, unless otherwise authorized by OFAC. This difference led, for instance, to Eni (an Italian energy company) continuing its deepwater exploration in the Black Sea in partnership with Russian state-controlled oil company Rosneft; by contrast, ExxonMobil withdrew from certain joint ventures with Rosneft in 2018 after failing in April 2017 to secure a waiver from the Treasury Departmentfrom the Department of the Treasury to move forward with its own oil exploration project in the Black Sea.126 Sea.¹³⁵

Neither the United States nor the EU has employed sectoral sanctions that broadly target Russia's ’s gas sector or state-controlled gas company Gazprom. Reports suggest that as the United States and EU worked to develop sanctions on Russia in 2014, they agreed to avoid measures that could harm the other'’s interests, including in relation to the production and supply of Russian gas.¹³⁶127 As discussed above, many EU countries dependent on Russian gas supplies were particularly worried 125 Jeevan Vasagar, “Russia Sanctions Take Toll on Germany,” Financial Times, August 25, 2014; Sabrina Tavernise, “Canceling Deal for 2 Warships, France Agrees to Repay Russia,” New York Times, August 5, 2015; and Aaron Mehta, “Inside America’s Multimillion-Dollar Plan to Get Allies Off Russian Equipment,” Defense News, May 29, 2019. 126 Jack Farchy and Chiara Albanese, “Sanctions-Proof Oil Rig Thwarts U.S. Policy from Cuba to Russia,” Bloomberg, December 19, 2017; and Henry Foy and Ed Crooks, “ExxonMobil Abandons Joint Ventures with Russia’s Rosneft,” Financial Times, March 1, 2018. 127 Deutsche Welle, “U.S. Sanctions Experts: European Concerns Are Exaggerated,” July 28, 2017; and Boris Toucas, “Russia Sanctions Act Is Enacted: Is President Trump Europe’s Best Ally in Managing the Impact on the Transatlantic Link?” Center for Strategic and International Studies, August 4, 2017. Congressional Research Service 37 U.S. Sanctions on Russia discussed above, many EU countries dependent on Russian gas supplies were particularly worried about sanctions that could impede the flow of Russian gas and harm relations with Russia in this area. The United States and EU dothe EU apply financial restrictions to two Gazprom subsidiaries (Gazpromneft, its oil production and refining subsidiary, and Gazprombank, a financial institution), and the. U.S. restrictions on deepwater, Arctic offshore, and shale oil projects also specifically apply to Gazprom. In addition, the United States applies lending restrictions to Novatek, a private Russian gas company. Neither the United States nor the EU has applied sanctions targeting gas production or trade.

Developments Since 2017

Given previously gas and oil trade. EU Concerns About U.S. Sanctions After 2017 Given close U.S.-EU coordination on sanctions related to Russia'’s invasion of Ukraine, some in the EU became concerned from 2017the EU have been concerned about what they viewviewed as a more unilateral U.S. approach since 2017to sanctions. Many in the EU were dismayed, for example, by certain provisions in CRIEEA as the legislation evolved. European leaders and EU officials recognized that the main intent of CRIEEA was to codify and strengthen sanctions on Russia, including many with parallels in EU legislation. At the same time, European policymakers were uneasy with some of CRIEEA'’s initial provisions, which they viewed as having been drafted without regard for the EU'’s role as a U.S. partner. s role as a U.S. partner.

EU concerns were accommodated to some degree by language inserted in CRIEEA specifying that the President should "“continue to uphold and seek unity"” with European partners on sanctions (§212) and that new U.S. sanctions on pipeline ventures would not be imposed without coordinating with U.S. allies (§232). Following CRIEEA'’s enactment, the European Commission (the EU'’s executive) expressed overall satisfaction that "“European interests can thus be taken into account in the implementation of any [U.S.] sanctions."¹³⁹ State Department guidance issued in October 2017 stated that the United States would not impose any such sanctions without coordination with U.S. allies.¹⁴⁰

”128 Nonetheless, some European officials and experts arewere skeptical of the Trump Administration's ’s commitment to consult the EU and its member states ahead of imposing new sanctions, especially amid broader European concerns about whether the Administration regards the EU as a partner or a competitor. Those of this view pointpointed, for example, to the Trump Administration'’s April 2018 designation of several Russian billionaires and the companies they control. Some media reports suggested the Trump Administration issued these designations without significant prior consultations with the EU or leading European governments.¹⁴¹

129 In particular, the designation of Rusal, a leading global producer of aluminum and the raw material alumina, had potentially significant implications for Europe'’s aluminum and manufacturing sectors. Concern that the Administration would enforce CRIEEA'’s secondary sanctions against European firms that have commercial and financial dealings with Rusal (whose facility in Ireland supplies many European aluminum producers) effectively halted such transactions. The U.S. announcement also led to a rise in the price of alumina. European officials warned that sanctions on Rusal could lead to plant closures, job losses, and the supply and production chains of key European industries, ranging from the makers of aluminum cans and foil to automobile and aerospace companies.¹⁴²

The Trump Administration appears to have been130 128 European Commission, “European Commission President Juncker: New U.S. Sanctions on Russia Only After Consultation of Allies,” August 2, 2017. 129 Ian Talley and Amrith Ramkumar, “U.S Extends Deadline for Investors to Disentangle from Rusal,” Wall Street Journal, April 23, 2018. 130 Neil Hume, Guy Chazan, and Harriet Agnew, “Europe in Diplomatic Push to Ease Russia Sanctions,” Financial Times, April 20, 2018. Congressional Research Service 38 link to page 29 link to page 31 link to page 31 U.S. Sanctions on Russia The Trump Administration appeared responsive to subsequent European entreaties (and those of other international partners, such as Brazil) regarding the difficulties posed for them by Rusal's ’s designation. Then-Treasury Secretary Mnuchin indicated that the "“impact on our partners and allies"allies” contributed to a U.S. decision to extend the wind-down period for transactions with Rusal.¹⁴³131 In January 2019, the Department of the TreasuryTreasury Department removed sanctions on Rusal and two related companies (see "“Section 241 “Oligarch” List and Related Sanctions,” above). InSection 241 "Oligarch" List," above).

In December 2019, U.S.-EU tensions again arose over the enactment of PEESA, which established new sanctions related to the construction of the Nord Stream 2 pipeline (see "Energy Export Pipelines."“Nord Stream 2: Energy Exports as a Coercive or Political Tool,” above). Despite reservations about Nord Stream 2 within the European Commission and among some EU member states, EU officials have asserted strong opposition to PEESA, noting that the EU rejects as a "“matter of principle"” the imposition of sanctions against EU companies conducting legitimate business in line with EU and European law.132 The Trump Administration did not impose sanctions under PEESA (although on President Trump’s last full day in office, the Trump Administration imposed Nord Stream 2-related sanctions under Section 232 of CRIEEA). The Biden Administration has sought to assuage these concerns and prioritize coordination with the EU in imposing further sanctions on Russia. None of the sanctions the Biden Administration has imposed pursuant to PEESA target European-based individuals or entities. In addition, U.S. officials explained a May 2021 decision to waive the application of new sanctions on the Swiss-based (but Russian-owned) Nord Stream 2 AG company and its corporate officers (some of whom are EU citizens) as “in line with the President’s commitment to rebuild relations with our allies and intended to create space for diplomacy with Germany to address the risks an operational Nord Stream 2 pipeline would pose to European energy security and to Ukraine and frontline NATO and EU countries.”133 Other EU Sanctions in Response to Russian Activities U.S. officials also have highlighted coordination with the EU in imposing sanctions in response to Russia’s alleged use of chemical weapons, cyberattacks, and human rights abuses. The March 2018 nerve agent attack in the UK reportedly perpetrated by Russian military intelligence agents helped spur the EU to agree to a broad new sanctions regime in October 2018 targeting individuals and entities involved in the development and use of chemical weapons.134 In January 2019, the EU imposed sanctions under this new regime on four GRU officers believed responsible for or involved in carrying out the attack (including the head and deputy head of the GRU). In October 2020, the EU imposed another round of chemical weapons sanctions on six senior Russian officials and a Russian research institute in response to the chemical weapon attack on Russian opposition figure Navalny. In May 2019, the EU established a new framework enabling it to impose sanctions aimed at deterring and responding to cyberattacks. These could be imposed on individuals or entities directly responsible for cyberattacks or for providing support for such attacks. In July and 131 U.S. Department of the Treasury, “Treasury Extends Wind-Down Period for United Company RUSAL PLC,” press release, April 23, 2018. 132 BBC News, “Nord Stream 2: Germany and Russia Decry U.S. Sanctions,” December 21, 2019; and RFE/RL, “European Commission President Criticizes U.S. Nord Stream Sanctions,” December 27, 2019. 133 U.S. Department of State, “Briefing with Senior State Department Officials On European Energy Security,” July 21, 2021. 134 Council of the EU, “Chemical Weapons: The Council Adopts a New Sanctions Regime,” October 15, 2018. Congressional Research Service 39 link to page 44 U.S. Sanctions on Russia October 2020, the EU used this new regime to impose sanctions against six Russian individuals and two entities for a 2015 cyberattack against the German federal parliament, the 2017 “NotPetya” global ransomware attack, and the 2018 attempted attack against the OPCW.135 In December 2020, the EU established a new human rights sanctions regime targeting individuals “responsible for, involved in or associated with serious human rights violations and abuses worldwide, no matter where they occurred.”136 For many years, some European leaders and EU officials—including some members of the European Parliament—had called for an “EU Magnitsky Act” that would target Russians (and others) complicit in human rights abuses. In March 2021, the EU coordinated with the United States to impose sanctions against four Russian officials, including Russia’s prosecutor general, under this new regime. The EU also has imposed human rights sanctions on two officials from Russia’s Chechen Republic. law.¹⁴⁴

Potential New EU Sanctions on Russia

Following the Skripal attack, some UK parliamentarians and analysts began calling for additional financial sanctions on Russia, including possibly banning financial clearinghouses from selling Russian sovereign debt. Experts note that any such sanctions likely would be more effective if imposed by the EU, given that key European clearinghouses are not incorporated in the UK and would not be affected by unilateral UK sanctions. Many analysts are skeptical, however, that the EU would be able to achieve the required unanimity to impose such additional EU-wide sanctions on Russian financial activity.¹⁵⁴ Some analysts also suggest that the UK's scheduled departure from the EU in January 2020 may diminish the prospects for any further EU sanctions targeting Russia's sovereign debt.

Economic Impact of Sanctions on Russia

Russian Economy Since 2014

In 2014 and 2015, Russia faced serious economic challenges and entered a two-year recession (Figure 1), its longest in almost 20 years.¹⁵⁵ Investor sentiment collapsed, resulting in capital flight, a collapse in the value of the ruble, and inflation (Figure 1 and Figure 2). The Russian government and many Russian firms (including firms not subject to sanctions) were broadly shut out of capital markets.¹⁵⁶ The government's budget deficit widened, and it tapped reserves to finance spending, defend the value of the ruble, and recapitalize banks affected by sanctions. Between the end of 2013 and May 2015, Russia's international reserves fell by about one-third.¹⁵⁷

Oil prices began to rise in 2016. Although they have not reached pre-2014 levels, the uptick helped to stabilize Russia's economy. The rate of economic contraction slowed, inflation fell, and the value of the ruble stabilized Economic Impact of Sanctions on Russia Impact on Russia’s Economy Broadly U.S. sanctions imposed on Russia in 2014 and in subsequent years appear to have had a negative impact on Russia’s overall economy, although the size of the impact is modest compared with other economic shocks. In particular, Russia’s economy arguably has been impacted more significantly by changes in the global price for oil—Russia’s main export and source of revenue—and the economic disruptions associated with the COVID-19 pandemic than by sanctions. In 2014, Russia faced, in addition to new multilateral sanctions, a collapse in global Figure 1. Economic Growth in Russia, oil prices. Historically, fluctuations in 1994-2021 Russia’s economy have been closely correlated with fluctuations in global oil prices (Figure 1). Growth slowed to 0.7% in 2014, and the economy contracted by 2.0% in 2015. The 2014-2015 recession was, at the time, Russia’s longest in almost 20 years.137 However, as oil prices recovered, Russia’s economy stabilized and grew at a modest pace between 2016 and 2019 (on average 1.5%), even as some sanctions were tightened and expanded. The International Monetary Fund (IMF) estimates that, between 2014 and 2018, Source: IMF, World Economic Outlook Database, the fall in oil prices had about three times October 2021. the effect of sanctions on Russia’s 135 Council of the EU, “EU Imposes the First Ever Sanctions Against Cyber-attacks,” July 30, 2020; and Council of the EU, “Malicious Cyber-attacks: EU Sanctions Two Individuals and One Body over 2015 Bundestag Hack,” October 2020. 136 Council of the EU, “EU Adopts a Global Human Rights Sanctions Regime,” December 7, 2020. 137 Kathrin Hille, “Russia: Putin’s Balance Sheet,” Financial Times, April 7, 2016. Congressional Research Service 40 link to page 61 link to page 61 link to page 6 U.S. Sanctions on Russia economy. In particular, the IMF estimated in August 2019 that sanctions led growth to fall short of expectations by about 0.2% per year since 2014. In comparison, according to IMF estimates, the decline in global oil prices caused Russian growth to be about 0.6% lower than expectations each year since 2014.138 Russia’s economy in 2020 was impacted largely by the disruptions in economic activity associated with the COVID-19 pandemic and a sharp downturn in oil prices. The economy contracted by about 3.0% in 2020. Russia’s economy rebounded sharply in 2021, by an estimated 4.7%, supported by higher oil prices and various factors mitigating the pandemic’s economic impact (including Russia’s relatively small service sector and the government’s strong fiscal and monetary policy response).139 Many economists view sanctions as a continued drag on economic growth in Russia, along with a host of other structural problems in the economy (including corruption and an ageing population).140 The modest macroeconomic effects of sanctions were largely by design of the Obama Administration, the EU, and other international counterparts when they instituted sanctions in response to Russia’s invasion of Ukraine in 2014. These sanctions do not broadly prohibit economic activity with Russia. They were intended to be smart sanctions that target individuals and entities responsible for offending policies and/or associated with key Russian policymakers but inflicted minimal collateral damage to the Russian people and to the economic interests of countries imposing sanctions.141 For example, more than half of the U.S. sanctions that block assets and restrict transactions target individuals, not firms. Such sanctions may be consequential for the specific individuals involved and may send important political messages, but they are unlikely to have broader effects on Russia’s economy. Sanctions that block assets and restrict transactions on entities are mainly limited to businesses controlled by designated individuals, companies that operate in Crimea, and several defense and arms firms. Of Russia’s 20 largest firms, one (Rosoboronexport) is subject to full blocking sanctions (Table E-1).142 More major Russian companies (9 of Russia’s 20 largest firms) are subject to sectoral sanctions, which impose narrower restrictions on debt (and, in some cases, equity) and/or oil exploration projects (Table E-1). Some sectoral sanctions were designed to make it harder for Russia to modernize its oil sector with access to Western technology and capital. In 2016, a State Department official explained that such sanctions were not designed to push Russia “over the economic cliff” in the short run but to exert long-term pressure.143 Impact on Russian Firms Even as the effects of sanctions on Russia’s economy as a whole have been relatively modest, their impact on specific firms and sectors in some cases has been more significant. One study 138 IMF, Russian Federation: Staff Report for the 2019 Article IV Consultation, August 2019, p. 5. 139 IMF, Russian Federation: Staff Report for the 2020 Article IV Consultation, February 2021. 140 Ibid. 141 Ahn and Ludema, “The Sword and the Shield,” 2020 (footnote 1). 142 Congressional Research Service (CRS) analysis of data published by Russian media outlet RBC (https://www.rbc.ru/rbc500/) on the largest firms in Russia and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons (SDN) List and Sectoral Sanctions Identifications (SSI) List. 143 Robin Emmott, “Sanctions Impact on Russia to be Longer Term, U.S. Says,” Reuters, January 12, 2016. Congressional Research Service 41 link to page 6 U.S. Sanctions on Russia uses firm-level data to estimate the impact of U.S. and European sanctions in 2014 on Russian firms.144 Based on data from between 2012 and 2016, the study finds that sanctioned firms on average lost about one-quarter of their operating revenues, over one-half of their asset values, and about one-third of their employees relative to their non-sanctioned peers. The authors argue that the findings suggest sanctions effectively targeted firms with relatively. The Russian government and non-sanctioned Russian entities resumed some access to international capital markets, capital outflows slowed, and foreign direct investment into Russia rebounded (Figure 2). At the same time, 2016 was a difficult fiscal year; the Russian government relied heavily on funding from one of its sovereign wealth funds and was forced to partially privatize Rosneft, the prized state-owned oil company, to raise funds.

However, Russia continues to face long-term economic challenges relating to limited progress on structural reforms and adverse demographic changes. Analysts have characterized Russia's economy as surviving, not thriving.¹⁶⁰ In 2019, the IMF projected that, absent deeper structural reforms, long-run growth in Russia will settle around a relatively modest 1.8% per year.¹⁶¹ At the same time, sanctions continue to constrain the ability of some Russian firms, particularly in the banking sector, to access financing (Figure 2).

Figure 1. Russia: Key Macroeconomic Indicators

Source: International Monetary Fund (IMF), World Economic Outlook, October 2019; IMF Exchange Rate Database; Central Bank of Russia, International Reserves of the Russian Federation (End of Period), accessed November 20, 2019. Based on current dollars/rubles. Note: Dashed lines indicate data estimates and projections.

Figure 2. Russia and International Capital Markets

Source: Central Bank of Russia, "Financial Transactions of Private Sector," "Direct Investment in the Russian Federation: Positions by Instrument and Partner Country (Asset/Liability Principle)," and "External Debt of the Russian Federation in National and Foreign Currency: Detailed Analytical Position," at https://www.cbr.ru/eng/, accessed November 21, 2019. Based on current dollars/rubles. Note: * denotes estimated data (capital outflows and FDI) or partial year data (external debt).

Estimates of the Broad Economic Impact

Factors Influencing the Broad Economic Impact

Russia's economic recovery in 2016-2017 occurred while sanctions remained in place and, in some instances, were tightened. As a result, some have questioned why the sanctions have not had a greater economic impact. A key factor is that the Obama Administration, the EU, and other international counterparts designed sanctions related to Russia's invasion of Ukraine, which account for most U.S. and international sanctions on Russia, to have a limited and targeted economic impact. The sanctions do not broadly prohibit economic activity with Russia. They were intended to be "smart sanctions" that targeted individuals and entities responsible for offending policies and/or were associated with key Russian policymakers but inflicted minimal collateral damage to other Russian firms. Media reports also provide anecdotal examples of how sanctions have created economic frictions at the firm level. For example, Rostec, a major state-owned defense conglomerate, saw profits drop in 2014 from a loss in foreign investment caused by sanctions, Exxon canceled its involvement in a joint venture with state-owned oil company Rosneft to comply with U.S. sanctions requirements, and sanctions reportedly forced Rosneft to suspend an oil project in the Black Sea.145 Media reports about the firm-level effects of sanctions appear to have become less common in recent years, presumably as firms have adjusted to the sanctions. Some Russian firms have weathered sanctions better than others. This discrepancy may be attributable to a number of factors. First, the extent to which sanctions interrupted economic transactions varies across sanction targets. It is not clear to what extent some sanctioned targets, including Russian intelligence services, the Night Wolves (a motorcycle club), or the Eurasian Youth Union, engage in significant economic transactions with the United States or in the U.S. financial system.146 Such sanctions may be more symbolic than disruptive of economic activity. Additionally, the limited design of the sectoral sanctions did not necessarily result in a rapid disruption in business operations, particularly as oil prices rose. Despite sectoral sanctions, Russian energy firms largely have been able to carry on business as normal.147 Russian oil production reached record highs in 2018, despite restrictions on access to Western technology for certain oil exploration projects.148 Russian oil exports to the United States have grown.149 Second, the Russian government has implemented various measures to support some sanctioned firms. The support measures include central bank purchases of sanctioned banks’ debt, granting government contracts to sanctioned firms, and recapitalizing sanctioned banks.150 More broadly, the government created a department within the Finance Ministry to liaise with sanctioned businesses, study their challenges, and draft government proposals for support.151 Although it is 144 Ahn and Ludema, “The Sword and the Shield,” 2020 (footnote 1); and Todd Prince, “Western Sanctions Have Had ‘Outsized Impact’ on Russian Companies, Economist Says,” RFE/RL, December 8, 2020. 145 Moscow Times, “Sanctions Hit Profits at Russian Defense and Technology Giant Rostec,” July 22, 2015; Chris Isidore and Matt Egan, “ExxonMobil Drops Out of Russian Joint Venture Due to Sanctions,” CNN, March 1, 2018; and Elena Holodny, “Russian Oil Behemoth Rosneft Reportedly Suspends an Oil Project in the Black Sea Because of Western Sanctions,” Business Insider, October 30, 2017. 146 RFE/RL, “Q&A: Ex-White House Official Says New Russia Sanctions Will Have ‘Marginal, If Any, Impact,’” March 15, 2018. 147 Henry Foy, “Russian Energy Groups Largely Unscathed by Western Sanctions,” Financial Times, March 15, 2018. 148 Vladimir Soldatkin, “Russian Oil Output Reaches Record High in 2018, Reuters, January 2, 2019.. 149 Eklavya Gupte, “Analysis: US Reliance on Russian Oil Hits Record High Despite Souring Ties,” S&P Global, April 16, 2021. 150 See, for example, Bud Coote, “Impact of Sanctions on Russia’s Energy Sector,” Atlantic Council, March 2018; Leonid Bershidsky, “Some Sanctioned Russian Firms Thrive on Adversity,” Bloomberg, May 8, 2018; Henry Foy, “Russia: Adapting to Sanctions Leaves Economy in Robust Health,” Financial Times, January 29, 2020; and Moscow Times, “Russian State Firms Allowed to Hide Public Contracts as U.S. Sanctions Loom, November 30, 2021. 151 Olga Tanas and Katia Dmitrieva, “Russia’s Sanctioned Companies Seek $1.6 Billion in State Support,” Bloomberg, April 20, 2018. Congressional Research Service 42 U.S. Sanctions on Russia difficult to find a precise quantitative estimate of the extent to which the Russian government has used resources to shield firms from sanctions, such support shifts the cost of sanctions from the targeted firms to the government. Third, some Russian firms have minimized the sanctions’ impact by pursuing import substitution policies and forging alternative economic partnerships. The Russian government has found alternative suppliers for its military modernization, particularly from China, South Korea, and Southeast Asia. Russian energy firms have concluded a number of corporate agreements with Chinese and Saudi companies following the imposition of sanctions.152 The extent to which Russia can successfully execute a “pivot to China” and other non-Western sources of financing, investment, and trade should not be overstated, however. CRIEEA’s sanctions against third parties that engage in significant transactions with Russia’s defense and intelligence sectors, as well as CRIEEA’s introduction of a policy option to impose secondary sanctions against those that engage in significant transactions with sanctioned Russian individuals and firms more generally, means that these alternatives remain risky and uncertain. Impact on Russian Government Finances U.S. sanctions on transactions related to Russian sovereign debt strive to make it more difficult, and expensive, for the Russian government to borrow from international capital markets. The Russian government, like many other governments, raises money from international investors by selling bonds. In August 2019, the United States imposed restrictions on some U.S. transactions in Russian sovereign bonds (see “Use of a Chemical Weapon,” above) and tightened these restrictions in April 2021. U.S. sanctions prohibit U.S. investors from purchasing Russian bonds when they are first sold (primary market transactions). Russian bonds, like other bonds, are frequently traded by investors, and sanctions permit U.S. investors to buy and sell Russian bonds after the initial bond auction (secondary market transactions). Some evidence suggests sanctions have impacted the market for Russian bonds. Tighter sanctions on Russian bonds in April 2021 caused foreign investors’ holdings of Russian government debt to fall below 20% for the first time in six years.153 Additionally, the Bank of Russia canceled several bond auctions in 2020 and 2021 due to insufficient bids, although it is unclear whether sanctions or other factors (such as rising interest rates in advanced economies) are the underlying cause.154 The impact of restrictions on trade and investment in Russian sovereign debt is mediated by two factors. First, these sanctions restrict specifically the initial sale of the bond, while permitting all subsequent transactions during the bond’s term to maturity, which can exceed 10 years. This means that the restriction against U.S. investors owning Russian bonds exists for a relatively small portion of the bond’s lifespan. Second, the Russian government has strong public finances and is generally not reliant on international investors to finance its budget. The government has 152 Richard Connolly and Philip Hanson, “Import Substitution and Economic Sovereignty in Russia,” Chatham House, June 2016; Paul Mcleary, “Did Western Sanctions Actually Help the Russian Military?” Foreign Policy, January 23, 2017; Henry Foy, “Russia Turns to New Friends from China and the Middle East,” Financial Times, October 11, 2017; Maria Shagina, Drifting East: Russia’s Import Substitution and Its Pivot to Asia, Center for Eastern European Studies, April 2020; and Alexander Gabuev, “As Russia and China Draw Closer, Europe Watches with Foreboding,” Carnegie Moscow Center, March 19, 2021. Also see CRS Report R46937, Russian Arms Sales and Defense Industry, by Andrew S. Bowen. 153 Jake Cordell, “Sanctions Threat Pushes Foreign Share of Russian Debt to 6-Year Low,” Moscow Times, April 6, 2021. 154 Bank of Russia, “Bank of Russia Bond Auction Results,” accessed December 2021. Congressional Research Service 43 U.S. Sanctions on Russia low levels of debt, large reserve holdings, and a large domestic market for Russian bonds (i.e., Russian investors willing to purchase government bonds). In April 2021, U.S. investors reportedly held about 7% of outstanding Russian sovereign bonds denominated in rubles.155 Russia’s De-Dollarization Efforts The dol ar has served as the world's dominant reserve currency since World War II. It is the primary currency used in cross-border transactions, held by central banks in reserves, and traded in foreign exchange markets. The role of the dol ar reflects global confidence in the U.S. Federal Reserve as an institution and the U.S. economy and financial markets more generally. Russia has long sought to reduce its reliance on the U.S. dol ar, with the government accelerating its efforts fol owing the expansion of U.S. sanctions in 2014. Taking a multipronged approach, the Russian government has, with varying degrees of success, sought to reduce the share of central bank foreign exchange reserves held in dol ars, reduce dol ar-denominated assets in its sovereign wealth fund, conclude agreements with other countries to conduct trade in national currencies, and develop alternative payment systems that are not centered on the dol ar. Russian President Vladimir Putin has acknowledged that Russia wil not be able to completely de-dol arize and referred to the dol ar as a “universal global currency.” However, if Russia and other countries, including China, successful y pivot from the U.S. dol ar, this could have implications for U.S. economic and foreign policy interests. Source: TASS Russian News Agency, “US Policy Undermines Dol ar’s Position as Reserve Currency—Putin,” November 30, 2021. For more, see CRS In Focus IF11885, De-Dollarization Efforts in China and Russia, by Rebecca M. Nelson and Karen M. Sutter. Outlook The United States and its allies have sustained sanctions on Russia since its 2014 invasion of Ukraine, and these sanctions are supported on a bipartisan basis in Congress. As the United States and other countries consider the possibility of new sanctions on Russia, debates about the impact and effectiveness of existing sanctions persist. Despite almost eight years of escalating sanctions, Russia has deepened its hold over Ukraine’s occupied Crimea region and separatist regions in eastern Ukraine. Russia has extended military operations to nearby waters and has engaged in a buildup of military forces near the Ukrainian border. Russian officials have intimated that Russia could take further military action in Ukraine in pursuit of Russia’s national security interests. The United States and other countries also have continued to document multiple incidents of Russian malicious cyber-enabled activities and influence operations worldwide. The United States and its allies have determined that Russian agents used lethal nerve agents to attack opponents in the UK and in Russia. Russia continues to be an influential supporter of the Syrian and Venezuelan governments and has deployed mercenaries accused of human rights abuses to multiple conflict zones. Some observers argue sanctions have restrained Russia somewhat or that the imposition of sanctions is an appropriate foreign policy response regardless of immediate effect.156 Others are skeptical that sanctions can produce desired changes in Russian behavior, at least without the use 155 Peter S. Goodman, Jack Ewing, and Matt Phillips, “Sanctions on Russian Debt are Called a ‘First Salvo’ that Sends a Message,” New York Times, April 15, 2021. 156 Masha Gessen, “The Moral Case for Sanctions Against Russia,” New Yorker, April 6, 2018; and Nigel Gould-Davies, “Sanctions on Russia Are Working,” Foreign Affairs, August 22, 2018. Congressional Research Service 44 U.S. Sanctions on Russia of other policy tools.157 Observers stress the importance of strengthening sanctions enforcement and coordinating with U.S. allies and partners.158 Looking ahead, the United States and its allies have said they would consider new sanctions on Russia in response to Russia’s military buildup near and in Ukraine. On December 7, 2021, President Biden held a video conference with President Putin in which he “made clear that the U.S. and our Allies would respond with strong economic and other measures in the event of military escalation” in Ukraine.159 On December 12, 2021, Secretary Blinken joined the six other Group of Seven (G7) foreign ministers and the EU High Representative for Foreign Affairs and Security Policy in asserting that “Russia should be in no doubt that further military aggression against Ukraine would have massive consequences and severe cost in response.”160 U.S. officials reportedly have conveyed examples of the kinds of additional sanctions under consideration, including greater restrictions on transactions with Russian financial institutions and U.S. technology exports. Some observers speculate that additional sanctions are possible, including sanctions targeting Russia’s energy sector, secondary market transactions in Russian sovereign debt, or Russia’s participation in international financial messaging services.161 With regard to Russia’s Nord Stream 2 natural gas pipeline to Germany, U.S. officials have said it would “be difficult to see gas flowing through” the pipeline in the event of further Russian aggression against Ukraine.162 German officials have not explicitly said Nord Stream 2 would be impacted. They have said, however, they would uphold a joint pledge with the United States “to limit Russian export capabilities to Europe in the energy sector, including gas, and/or in other economically relevant sectors” should Russia “commit further aggressive acts against Ukraine.”163 157 Andrea Kendall-Taylor, “U.S. Russia Policy: Moving Beyond Sanctions,” Center for a New American Security, January 23, 2019; and Maria Shagina, “Toward a Trans-Atlantic Strategy on Russia Sanctions,” War on the Rocks, December 6, 2021. 158 Anders Aslund and Maria Snegovaya, The Impact of Western Sanctions on Russia and How They Can Be Made Even More Effective, Atlantic Council, May 2021. 159 White House, “Readout of President Biden’s Video Call with President Vladimir Putin of Russia,” December 7, 2021. 160 U.S. Department of State, “G7 Foreign Ministers’ Statement on Russia and Ukraine,” December 12, 2021. 161 Paul Sonne, Ellen Nakashima, and Michael Birnbaum, “Amid Ukraine Invasion Scare, U.S. and Europe Lean on Sanctions Threat to Stop Putin,” Washington Post, December 22, 2021; and David E. Sanger and Eric Schmitt, “U.S. Details Costs of a Russian Invasion of Ukraine,” New York Times, January 8, 2022. 162 U.S. Department of State, “Secretary Antony J. Blinken and German Foreign Minister Annalena Baerbock at a Joint Press Availability,” January 5, 2022. 163 U.S. Department of State, “Joint Statement of the United States and Germany on Support for Ukraine, European Energy Security, and our Climate Goals,” July 21, 2022. Congressional Research Service 45 U.S. Sanctions on Russia Appendix A. to the Russian people and to the economic interests of countries imposing sanctions.¹⁷³

Sanctions related to Russia's invasion of Ukraine target specific individuals and firms. In some cases, they prohibit only specific types of transactions. Overall, more than four-fifths of the largest 100 firms in Russia (in 2018) are not directly subject to any U.S. sanctions, including companies in a variety of sectors, such as railway, retail, autos, services, mining, and manufacturing (Table D-1).¹⁷⁴ According to one independent Russian polling firm, 78% of individuals polled in April 2018 reported that they were largely unaffected by Western sanctions.¹⁷⁵

More than half of the U.S. SDN sanctions that block assets and restrict transactions target individuals, not firms. Such sanctions may be consequential for the specific individuals involved and may send important political messages, but they are unlikely to have broader effects on Russia's economy. SDN sanctions on entities are mainly limited to businesses controlled by designated individuals, companies that operate in Crimea, and several defense and arms firms. Of the 100 largest firms in Russia, 5 are subject to full blocking (SDN) sanctions (Table D-1).¹⁷⁶

In contrast, the sectoral (SSI) sanctions target large Russian companies, affecting 7 of Russia's 10 largest companies. However, they limit a specific set of transactions relating to debt, equity, and/or certain long-term oil projects (Table D-2). In terms of debt (and, in some cases, equity) restrictions, sanctions were intended to restrict the access of major Russian financial, energy, and defense firms to international markets. Many major Russian firms had borrowed heavily from international investors. Restricting their access to new financing from western capital markets was intended to disrupt their ability to refinance (rollover) existing debts. As their debts matured, this would force firms to make large repayments or scramble for alternative sources of financing.

The sectoral sanctions restricting certain oil projects sought to put long-term pressure on the Russian government by denying Russian oil companies access to Western technology to modernize their industry or develop new sources of oil. In 2016, a State Department official explained that sanctions were not designed to push Russia "over the economic cliff" in the short run but to exert long-term economic pressure on the country.¹⁷⁷ By design, the full economic ramifications of restrictions on oil projects may have yet to materialize fully. The IMF estimated that lower capital accumulation and technological transfers resulting from sanctions could reduce Russia's output in the longer term by up to 9%; in contrast, it estimated the short-term impact of the sanctions as much smaller, between 1.0% and 1.5%.¹⁷⁸

Impact on Russian Firms and Sectors

The study estimates the average effects on sanctioned firms and provides only a snapshot of the sanctions' effects. Some sanctioned firms did worse than average; other sanctioned firms did well. For example, the ruble-denominated profits of Sberbank (the largest bank in Russia), Rostec (a major defense conglomerate), and Novatek (an independent natural gas producer) were higher by 2018 than when sectoral sanctions were imposed in 2014 (see Table D-2).¹⁹⁰

Factors Influencing the Impact on Firms and Sectors

Third, some Russian firms have minimized the sanctions' impact by forging alternative economic partnerships. For example, sanctions had the potential to jeopardize Russia's military modernization program, but Russia ultimately found alternative suppliers, particularly from China, South Korea, and Southeast Asia.²⁰³ Additionally, independent gas company Novatek secured alternative financing from China to proceed with a natural gas project in the Arctic.²⁰⁴ Gazprom secured a $2 billion loan from the Bank of China, the largest loan from a single bank in Gazprom's history.²⁰⁵ More generally, Russian energy firms have concluded a number of corporate agreements with Chinese and Saudi companies following the imposition of sanctions.²⁰⁶

Outlook

Appendix A. Legislative Abbreviations and Short Titles

CAATSA: Countering America'’s Adversaries Through Sanctions Act (P.L. 115-44)

) CBW Act: Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (P.L. 102-182, Title III; 22 U.S.C. 5601 et seq.)

CRIEEA: Countering Russian Influence in Europe and Eurasia Act of 2017, as amended (P.L. 115-44, Title II; 22 U.S.C. 9501 et seq.)

Global Magnitsky Act: Global Magnitsky Human Rights Accountability Act (P.L. 114-328, Title XII, Subtitle F; 22 U.S.C. 2656 note)

IEEPA: International Emergency Economic Powers Act (P.L. 95-223; 50 U.S.C. 1701)

et seq.) INKSNA: Iran, North Korea, and Syria Nonproliferation Act, as amended (P.L. 106-178,; 50 U.S.C. 1701 note)

NEA: National Emergencies Act (P.L. 94-412; 50 U.S.C. 1621)

1601 et seq.) PEESA: Protecting Europe'’s Energy Security Act of 2019 (P.L. 116-92, Title LXXV)

; 22 U.S.C. 9526 note) Sergei Magnitsky Act: The Sergei Magnitsky Rule of Law Accountability Act of 2012 (P.L. 112-208208, Title IV; 22 U.S.C. 5811 note)

SSIDES: Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014, as amended (P.L. 113-95; 22 U.S.C. 8901 et seq.)

UFSA: Ukraine Freedom Support Act of 2014, as amended (P.L. 113-272; 22 U.S.C. 8921 et seq.)

Appendix B. Congressional Research Service 46 link to page 56 link to page 56 link to page 56 U.S. Sanctions on Russia Appendix B. U.S. Sanctions on Russia U.S. Sanctions on Russia

Appendix C. U.S. and EU Sectoral Sanctions