New US sanctions target Russia for use of chemical weapons

The US has imposed new sanctions against Russia for its use of chemical weapons.

In August 2018, the US imposed sanctions against Russia in response to Russia's nerve agent attack against UK citizen and former Russian military intelligence officer Sergei Skripal and his daughter. The sanctions were issued under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the "CBW"), which mandates sanctions against any country determined to have used chemical or biological weapons in violation of international law or against their own nationals. 

The CBW also requires that the US impose additional sanctions against Russia if it fails to provide reliable assurances that it will not engage in chemical weapon attacks in the future. Last week, on 2 August 2019, the US Department of State announced that it was imposing additional sanctions because Russia had not provided such assurances. 

Subject to certain limited exceptions, the new sanctions on Russia will include:

i.  US opposition to the extension of any loan or financial or technical assistance to Russia by international financial institutions, such as the World Bank or International Monetary Fund (already existing);

ii.  Prohibition on US banks from participating in the primary market for non-ruble denominated Russian sovereign debt and lending non-ruble denominated funds to the Russian government; and

iii.  Licenses for the exports to Russia of dual-use chemical and biological items controlled by the US Department of Commerce will be subject to a "presumption of denial" policy. 

The sanctions aim to restrict Russia's access to the multilateral development bank system and to US-origin items that are strategically important to Russia's chemical and biological weapons program. According to a US Department of State Fact Sheet, the new sanctions could "curtail Russia‚Äôs access to billions of dollars of bilateral commercial activity with the United States". 

The sanctions are expected to take effect at the end of August 2019 and will remain in place for at least 12 months. 

For further information, see also US Department of Treasury's press release, OFAC's Notice and OFAC's new FAQs.