Key takeaways

• To implement the Countering America’s Adversaries through Sanctions Act (the “CAATS Act”), the U.S. Treasury Department has amended U.S. sectoral sanctions against Russia, effective November 28, to bar U.S. persons from transactions in debt of over 14 days' maturity of designated Russian financial services firms or over 60 days' maturity of designated Russian energy firms.
• President Trump concurrently issued a presidential memorandum delegating certain functions and authorities of the CAATS Act, principally to the Secretaries of State and Treasury.
• Senators Cardin and McCain sent an open letter to President Trump calling for broad implementation of the CAATS Act, particularly in regard to the defense and energy sectors.