Countering America’s Adversaries Through Sanctions Act (CAATS Act) Deadlines, Time Frames, and Start Dates

Countering America’s Adversaries Through Sanctions Act (CAATS Act) Deadlines, Time Frames, and Start Dates

Updated January 11, 2018
Countering America’s Adversaries Through Sanctions Act
(CAATS Act) Deadlines, Time Frames, and Start Dates
The Countering America’s Adversaries Through Sanctions
 Section 106(a) – State Department identifies persons
Act (CAATS Act; P.L. 115-44, signed into law August 2,
responsible for extrajudicial killings, torture, other
2017) requires a number of actions or reports of the
human rights violations against Iranian whistleblowers,
executive branch within a specific timeframe, by a deadline,
human rights defenders, or their supporters (annually
or starting from a specific date. The CAATS Act has three
thereafter).
titles, each dedicated to a particular U.S. economic
 Section 110 – Report on U.S. citizens held by Iran or
sanctions regime: Title I, Countering Iran’s Destabilizing
groups supported by Iran, and U.S. efforts to secure
Activities Act of 2017; Title II, Countering Russian
their release (President; unclassified, classified) (every
Influence in Europe and Eurasia Act of 2017; and Title III,
180 days thereafter).
Korean Interdiction and Modernization of Sanctions Act.
 Section 223 – Modify Directive 4 to Executive Order
The act also creates new authorities or amends existing
13662, affecting exports allowed for oil exploration in
authorities for the President to impose economic sanctions
Russia (Secretary of the Treasury).
at his discretion or based on his determinations and

certifications; see CRS In Focus IF10694, Countering
Section 255 – Report on media organizations controlled
America’s Adversaries Through Sanctions Act.
or owned by Russian government (President;
unclassified, classified) (ends August 2, 2022).
Action Due By September 1, 2017 (30 days)
 Section 256 – Report on funds provided by Russian
 Section 225 – Requires President, on or after this date,
Russia to influence elections in Europe or Eurasia
to impose Ukraine Freedom Support Act (UFSA)-
(President; unclassified, classified) (ends August 2,
defined sanctions on any “foreign person [who]
2022).
knowingly makes a significant investment in a special
Russian crude oil project,”

unless he determines that it is
Section 324 –Secretary of State reports on “whether
not in the national interest (previously discretionary).
North Korea meets the criteria for designation as a state
sponsor of terrorism” (unclassified, classified).
 Section 226(2) – Requires President, on or after this
date, to impose restrictions on any foreign financial
Action Due By January 29, 2018 (180 days minus 10
institution that facilitates transactions for any Russian
days)
Specially Designated National (SDN) unless he
 Section 333 – President notifies Congress not fewer than
determines that it is not in the national interest
10 days prior to issuing regulations to implement the
(previously discretionary).
North Korea title.
Action Due By October 1, 2017 (60 days)
Action Due By January 29, 2018 (180 days)
 Section 223 – Modify Directives 1 and 2 to Executive
 Section 103 – Regional strategy for deterring
Order 13662, pertaining to length of maturity for certain
conventional and asymmetric Iranian activities and
short-term debt, targeting Russia entities for Ukraine-
threats (State, Defense, the Treasury, Director of
related activities (Secretary of the Treasury).
National Intelligence (DNI); unclassified, classified)
 Section 224 – Requires President, on or after this date,
(every two years thereafter).
to issue sanctions—based on International Emergency
 Section 104 – Report on persons contributing to Iran’s
Economic Powers Act (IEEPA) authorities, or defined
ballistic missile program in previous 180 days
in Section 235 of the Act or Section 4 of the UFSA—
(President; unclassified, classified) (every 180 days
targeting Russia’s illicit cyber activities.
thereafter).
 Section 231 – President issues regulations or other
 Section 109 – Report on US-EU coordination on Iran-
guidance to define “persons that are part of, or operate
related sanctions over previous 180 days (President;
for or on behalf of, the defense and intelligence sectors”
unclassified, classified) (every 180 days thereafter).
of the Russian government, in anticipation of sanctions

required at 180 days (January 29, 2018).
Section 231 – President, on and after this date, imposes
Section 235 sanctions on those engaging in a significant
Action Due By October 31, 2017 (90 days)
transaction with a person who is part of, or operates for
 Section 105 – President imposes IEEPA-based sanctions
or on behalf of, Russia’s defense or intelligence sector.
on Iran Revolutionary Guard Corps (IRGC) and foreign
President may waive application with certification every
persons that are IRGC affiliates, officials, or agents.
180 days “that the person is substantially reducing the
number of significant transactions.”
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Countering America’s Adversaries Through Sanctions Act (CAATS Act) Deadlines, Time Frames, and Start Dates
 Section 241 – Report on Russian oligarchs and
 Section 318 – President briefs on international use of
parastatals, U.S. economic exposure to such persons,
specialized financial messaging services available to
effects of restrictions on debt and equity, potential
DPRK financial institutions (may be classified; every
impact of secondary sanctions (Secretary of the
180 days thereafter for five years).
Treasury, with State, DNI; unclassified, classified).
 Section 333 – Regulations to implement the North
 Section 242 – Report on expanding Russian sanctions to
Korea title. Not fewer than 10 days prior to issuing the
include sovereign debt and derivative products
regulations, President shall notify and provide the
(Secretary of the Treasury, with State, DNI;
proposed regulations to the appropriate congressional
unclassified, classified).
committees.
 Section 257 – Report on assisting Ukraine in its energy
Action Due By April 1, 2018 (explicit in legislation)
crisis in Ukraine, provided in Section 7(c) of UFSA,
 Section 254 – Report on programs and activities carried
with specific reporting on emergency energy assistance
out under the Countering Russian Influence Fund.
funding (Secretary of State) (every 180 days thereafter;
Report on funding provided to certain countries by the
congressional briefings 30 days after report; ends
European Union, EU and NATO countries, and
August 2, 2022).
international organizations and “quasi-governmental
 Section 273 – Report on Treasury’s financial attachés
funding entities” (Secretary of State, through
and technical assistance advisors in U.S. embassies—
Coordinator of U.S. Assistance to Europe and Eurasia)
their work on terrorist financing, money laundering,
(every April 1 thereafter; terminates August 2, 2022).
proliferation financing (Secretary of the Treasury).

Action Due By April 29, 2018 (270 days)
Section 311 – President reports on whether there are
 Section 271 – Report on pilot project for Somali money
“reasonable grounds” to designate six specific entities,
transfers, addressing cross-border fund transfers and
individuals, and their affiliates as SDN for their North
other tools used in illicit finance activities (Secretary of
Korea activities as defined in the North Korea Sanctions
the Treasury).
and Policy Enhancement Act of 2016 (NKSPEA; P.L.
114-122) (unclassified, classified).
Action Due By August 2, 2018 (one year)
 Section 313 (amending §203, NKSPEA) – Report on
 Section 243 – Report on illicit finance (e.g., terrorism,
compliance of foreign countries to curtail arms
narcotics, proliferation, money laundering) relating to
trafficking involving North Korea (Secretary of State;
Russia (Secretary of the Treasury, with Attorney
unclassified, classified) (annually thereafter for five
General, DNI, Homeland Security, State; unclassified,
years).
classified) (annually through 2021).
 Section 314 (amending §205, NKSPEA) – Report on
 Section 261 – Strategy for combatting terrorism
foreign sea ports and airports that fail to implement U.N.
financing and related forms of illicit finance (President,
Security Council resolutions (UNSCR) relating to
through the Secretary of the Treasury, with Attorney
inspection of cargo to/from North Korea, with details on
General, State, Homeland Security, DNI, Office of
specific ports in China, Iran, Russia, and Syria.
Management and Budget, and Federal financing
(President; unclassified, classified) (annually thereafter
agencies and regulators; unclassified, classified)
for five years).
(updates January 31, 2020; January 31, 2022).
 Section 315 (amending the Ports and Waterways Safety
Action Due By January 31, 2020
Act at 33 U.S.C. 1232c) – Report identifying foreign
 Section 261 – First update of national strategy for
vessels over 300 gross tons owned or operated by or on
combatting the financing of terrorism and related forms
behalf of the government of North Korea or a DPRK
of illicit finance (see August 2, 2018).
person, an entity identified by the Section 205,
NKSPEA report, or a foreign government that does not
Action Due By January 31, 2022
comply with relevant UNSCR (Secretary overseeing
 Section 261 – Second update of national strategy for
Coast Guard; published with periodic updates).
combatting the financing of terrorism and related forms
 Section 316 – President reports on North Korea-Iran
of illicit finance (see August 2, 2018).
cooperation on ballistic missiles, chemical or biological
weapons, or conventional weapons programs, including
Action Due By August 2, 2022 (five years)

names of other foreign nationals that facilitate this
Section 108 – Review of Iran-related designations on
cooperation, and the relationship to UNSCR
the Department of the Treasury’s Office of Foreign
requirements (unclassified, classified; annually
Assets Control (OFAC) SDN list to determine role in
thereafter for five years).
Iran’s international terrorism or ballistic missile
program, and apply appropriate sanctions (President).
 Section 317 – President reports on others’ efforts to
comply with DPRK-related UNSCR (unclassified,
Dianne E. Rennack, Specialist in Foreign Policy
classified; annually thereafter for five years).
Legislation
IF10805

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Countering America’s Adversaries Through Sanctions Act (CAATS Act) Deadlines, Time Frames, and Start Dates

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https://crsreports.congress.gov | IF10805 · VERSION 3 · UPDATED