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tions broadly to include individuals, partnerships, associa-
tions, trusts, joint ventures, corporations, and groups
Section 9527 – Privatization of State-Owned Assets
The President must impose five or more § 9529 sanctions
against any person who knowingly makes or facilitates an
investment of $10,000,000 or more that directly and sig-
nificantly contributes to Russia’s ability to privatize state-
owned assets that unjustly benefits Russian government
officials or their close associates or family members.
Section 9528 – Arms Transfers to Syria
The President must impose sanctions on any foreign per-
son or entity that has knowingly provided Syria with signif-
icant support that materially contributes to Syria’s ability
to acquire or develop weapons of mass destruction, missile
capabilities, and other materials identified by the Arms Ex-
port Control Act, 22 U.S.C. § 2751 et seq.
Section 9529 – List of Potential Sanctions
The President’s trove of sanctions are as follows:
(1) Prohibition of Export-Import Bank loans and assistance;
(2) Export sanctions 2 ;
(3) Prohibition of loans from United States institution 3 ;
(4) Prohibition of loans from international financial institu-
tions, including but not limited to the World Bank and the
International Monetary Fund;
2
3
(5) Prohibitions on financial institutions ;
(6) Procurement sanctions ;
(7) Prohibitions on foreign exchange;
(8) Prohibitions on banking transactions;
(9) Prohibitions on property transactions;
(10) Ban on investment in equity or debt of sanctioned person;
(11) Exclusion of corporate officers of sanctioned entity;
(12) Sanctions on principal executive officers of sanctioned
entity.
Tellingly, the President, upon the recommendations of the
National Security Council and the Treasury, has broad dis-
cretion to impose a wide variety of sanctions on violating
parties.
2. Discretionary Sanctions: Section 9526 – Pipeline In-
vestments
The President may impose five or more § 9529 sanctions
upon determination that one knowingly invested in or en-
gaged in transactions for the purposes of construction of
Russian energy pipelines if (1) a single investment or ex-
change has a fair market value of $1,000,000 or more or (2)
multiple investments or exchanges collectively have an ag-
gregate fair market value of $5,000,000 or more. Id. § 9526.
3. Exemptions
Activities subject to requirements of the National Security
For example, banks from a sanctioned country cannot sell U.S. debt instruments or act as a financial repository for U.S. Government funds.
U.S. Government would not enter into a procurement contract (i.e. SAMS) with a sanctioned person/entity