On Friday, OFAC issued the following new Ukraine/Russia-related Frequently-Asked Question:
815. How does the U.S. government plan to implement the wind-down specified in Section 7503(d) of the National Defense Authorization Act for Fiscal Year 2020 (NDAA), also known as the Protecting Europe’s Energy Security Act of 2019?
Upon signature by the President on December 20, 2019, the provisions of Section 7503 of the NDAA immediately became effective. In order to comply with the wind-down provisions of Section 7503(d) of the NDAA, involved parties that have knowingly sold, leased, or provided vessels that are engaged in pipe laying at depths of 100 feet or more below sea level for the construction of Nord Stream 2 or Turkstream must ensure that such vessels immediately cease construction-related activity. Notwithstanding the above, good-faith wind-down exceptions may be made for the safety of the pipeline or safety and care of the crew aboard the vessel, the protection of human life, or maintenance to avoid any environmental or other significant damage, as further described in Section 7503(e). [12-20-2019]