US Sanctions Parties Involved in Nord Stream 2 Pipeline Project

On January 19, 2021, the US State Department announced the imposition of sanctions on Russia-based entity KVT-RUS and Russian-flagged vessel FORTUNA pursuant to Section 232 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), for “knowingly selling, leasing, or providing to the Russian Federation goods, services, technology, information, or support for the construction of Russian energy export pipelines.” Accordingly, KVT-RUS and the vessel FORTUNA have been added to OFAC’s SDN list. The State Department also announced, without further details, that “the United States will consider further actions in the near term, under CAATSA, and the Protecting European Energy Security Act (PEESA), as amended.” This action follows recent changes in US law and policy targeting Nord Stream 2 in particular, as discussed in our prior blog posts here and here. It is notable, however, that this action was taken under the 2017 CAATSA statute, and not under the more recent US laws. Non-US persons should be aware that US secondary sanctions may apply to activity involving the recently sanctioned Russian party and vessel. We will continue to monitor these developments.