On June 15, 2017, the United States Senate adopted S.722, incorporating the “Countering Russian Influence in Europe and Eurasia Act of 2017” and the “Countering Iran’s Destabilizing Activities Act of 2017,” by a vote of 98-2. The new law, assuming it is passed by the House and adopted,  would:

  • codify all existing Russia sanctions and designations (meaning the Trump Administration cannot unilaterally lift them) and require congressional review for any subsequent changes in licensing policy;
  • tighten existing sectoral sanctions against Russian state-owned energy, financial, and defense companies and threaten their expansion to the state-owned shipping, rail, and mining/metal sectors;
  • reinvigorate existing but currently unenforced secondary sanctions targeting Russia and add new secondary sanctions provisions targeting Russian pipeline transactions in particular (but leave those sanctions in the hands of the Trump Administration); and
  • expand authority to sanction Russian cyber-related activities.

With respect to Iran, the Sanctions Bill would impose a largely symbolic expansion of secondary sanctions against Iranian military activity and sharpen focus on the Iranian Revolutionary Guard Corps and its affiliates.

The bill now proceeds to the House for consideration, the timing of which is uncertain, and it is possible that further amendments will be made. However, given the margin of passage of the Sanctions Bill and the bipartisan negotiations resulting in its adoption, it appears that there is a good chance that the final legislation passed by the House will be broadly similar and will be adopted by a margin sufficient to override any veto by President Trump.

The linked memorandum provides an overview of the key provisions of the new legislation.  Please click here to read the full alert memorandum.