Shearman & Sterling LLP
Issue link: https://digital.shearman.com/i/1422677
4 Konstanta (a construction company), ca ship owner), and Ostap Sheremeta (a vessel involved in the pipeline's construction). Pursuant to E.O. 10439, OFAC designated each of the persons identified in the State Department's report. Observers noted that the latest measures are largely symbolic and are unlikely to stall completion of the pipeline. Potential Second S-400 Purchase Prompts New Sanction Threats to Turkey This month, attention again focused on Turkey's pursuit of defensive military equipment purchased from Russia in potential violation of U.S. sanctions. As we previously reported, last December, the U.S. imposed sanctions on Turkey's Presidency of Defense Industries pursuant to Section 231 of CAATSA for knowingly engaging in a significant transaction with Russia's defense industry. The sanctions were imposed in connection with the key NATO ally's purchase of the S-400 surface-to-air missile system from Rosoboronexport, Russia's main arms export entity. Reportedly, Turkey is poised to purchase its second batch of S-400 missiles, which U.S. political leaders have already warned will trigger additional sanctions. Presidents Putin and Erdogan held in-person meetings in late September, despite the U.S. State Department's statement that "any significant new Russian arms purchases [by Turkey] would risk triggering…sanctions separate from and in addition to those imposed in December 2020." Attack on Opposition Figure Navalny Prompts CBW Act Sanctions Russia's chemical weapons program and its targeting of dissident domestic actors together provoked additional U.S. action to address Russia's alleged role in the Novichok nerve agent attack against opposition figure Aleksey Navalny. On August 20, the State Department announced that the U.S. would impose a second round of restrictive measures pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the "CBW Act"). The announced sanctions include: 1. restrictions on the permanent imports of certain Russian-made firearms and ammunition, with new and pending import-permit applications subject to a policy of denial; and 2. additional restrictions on U.S. exports to Russia of nuclear and missile-related goods and technology, pursuant to the Export Control Reform Act of 2018. In addition to CBW Act sanctions, OFAC and the State Department together designated a host of individuals and entities, including two entities allegedly connected to Russia's chemical weapons program: the FSB Criminalistics Institute and State Institute for Experimental Military Medicine of the Ministry of Defense. OFAC also designated the following nine individuals for their alleged involvement in the attack on Navalny: • Alexey Alexandrovich Alexandrov, FSB Criminalistics Institute operative • Ivan Vladmirovich Osipov, FSB Criminalistics Institute operative • Vladimir Bogdanov, Chief of the FSB's Special Technology Center • Stanislav Makshakov, an FSB official and toxicologist • Konstantin Kudryavtsev, FSB Criminalistics Institute operative • Valdirim Panyaev, an FSB operative • Aleksei Sedov, Chief of the FSB's Service for the Protection of the Constitutional System and the Fight against Terrorism • Kirill Vasiliev, Director of the FSB Criminalistics Institute • Artur Aleksandrovich, former director of the 27th Scientific Center Meanwhile, pursuant to E.O. 14024—issued last quarter as an omnibus sanctions vehicle against Russia—the State Department designated two Russian Ministry of Defense scientific institutes: the 27th Scientific Center and the 33rd Scientific Research and Testing Institute. Both entities were designated for their alleged operation in the defense sector of the Russian economy. Specifically, the State Department alleges that both organizations engaged in activities to develop Russia's chemical weapons and weapons-delivery capabilities.