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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