Key takeaways

• Last week, the U.S. Departments of State and Treasury issued new guidance on the implementation of recent legislation imposing sanctions against Russia.
• The guidance pertains mostly to new “secondary sanctions,” which seek to discourage non-U.S. persons from engaging in certain targeted activities with or involving Russia.
• The guidance defines several key terms and narrows the potential scope of several  provisions, removing some uncertainty regarding how the U.S. government intends to apply these new sanctions.