lutionary Guard Corps (“IRGC”) and
affiliated foreign persons, and (4) hu-
man rights abuses occurring in Iran.
Id. §§ 9403-9406.
1. Mandatory Sanctions
Anyone the President determines has
knowingly engaged in activity mate-
rially contributing to Iranian ballistic
missile or WMD programs, their suc-
cessors, anyone owned or controlled
by them, anyone acting on their be-
half, and anyone providing support to
them must be subjected to sanctions.
Id. § 9403. In addition, anyone who
knowingly and materiality contrib-
utes, directly or indirectly, arms or
related materials to Iran or provides
training or other resources must be
sanctioned. Id. § 9606. Under both §
9403 and § 9606, all subject trans-
actions within reach of the U.S. will
be blocked, and any aliens responsi-
ble will be denied U.S. visas. Under
§ 9404, the President must impose
sanctions provided for by IEEPA, 50
U.S.C. § 1701 et seq., against the IRGC
and foreign persons who act on be-
half of the IRGC. 22 U.S.C. § 9404.
4. Presidential Waiver 1. Mandatory Sanctions
The President may waive require-
ments under §§ 9403 through 9407
for a maximum of 180 days upon
determination and report to the ap-
propriate congressional committees
that doing so is vital to U.S. national
security i. Section 9522 – Cyber Security and
Ukraine
Section 9522 codifies “sanctions pro-
vided for in Executive Orders relating
to blocking property of certain per-
sons contributing to the situation in
Ukraine.
Title II - Countering Russian In-
fluence in Europe and Eurasia
Act 1 Section 9523 – Expansion of OFAC
Directives
Section 9523 expands OFAC Direc-
tives by decreasing the period during
which U.S. individuals and entities
may transact in “new debt” of sanc-
tioned Russian sectors. The 30 days
permitted by Directive 1 has been
shortened to 14 days’ maturity as to
the financial services sector, and the
90 days permitted under Directive 2
has been shortened to 60 days’ matu-
rity as to the energy sector.
In sum, Title II sanctions target ac-
tivity involving Russia and certain
operations outside of Russia, spe-
cifically including (1) cybersecu-
rity, (2) transactions with Russian
intelligence or defense sectors, (3)
pipeline development, (4) invest-
ment or facilitation of privatization
of state-owned assets by Russia, and
(5) arms transfers to Syria. 22 U.S.C.
§§ 9524-9528. It also specifically sets
forth the U.S.’s objective to restore
Ukrainian sovereignty. Id. § 9546.
But for extremely limited exception,
the President must submit any action
to terminate or waive sanctions un-
der Title II for congressional review.
Id. § 9511.
2. Discretionary Sanctions
Persons responsible for human
rights violations may be sanctioned
by the President under § 9405, which
allows for blocking of all subject
transactions within U.S. reach.
3. Exemptions
The following are exempt from Title
I: (1) activities subject to require-
ments of the National Security Act,
50 U.S.C. § 3091 et seq.; (2) admis-
sion of an alien necessary for the
U.S. to comply with obligations to the
U.N.; and (3) provision of humanitar-
ian assistance to the people of Iran in
the form of agricultural commodities,
food, medicine, and medical devices.
22 U.S.C. § 9410.
1
Penalties for violating or at-
tempting to violate CAATSA
sanctions are provided for
by IEEPA, 50 U.S.C. § 1701 et
seq. Where possible, these
include civil penalties of
$250,000 or twice the trans-
action amount, and criminal
penalties up to a $1 million
fine and/or 20 years impris-
onment. 50 U.S.C. § 1705.
Title II is the most complex and lengthy portion of CAATSA by a significant margin.
Section 9524 – Additional Cyberse-
curity Sanctions
Section 9524 requires the President
to impose sanctions, namely asset
blocking and exclusion from the
U.S., against anyone the President
determines has knowingly engaged
in significant activity undermining
cybersecurity on behalf or for the
benefit of Russia. In addition, § 9524
requires the President to implement
sanctions against any person who
knowingly and materially supports
or provides financial services to any-
one engaged in such activity.
Section 9525 – Intelligence and De-
fense Transactions
Those who have knowingly engaged
in a significant transaction with the
Russian intelligence or defense sec-
tors will be subjected to no less than
five sanctions (See Section vii) pro-
vided in § 9529. Section 7 of the Ex-
ecutive Order 13849 defines parties
who may be subject to these sanc-
35