Know Your Sanctions Lists (Beyond the CSL) – CAATSA Section 231
Beyond the Consolidated Screening List, ECScreening provides data from a growing number of official U.S. and foreign government sanctions lists and other sources to bring useful information to subscribers.
One of these lists comes from Section 231 of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA). Administered by the Department of State, this CAATSA is not to be confused with the Department of the Treasury’s CAPTA List.
CAATSA directs the President to impose a number of sanctions on any person that “engages in a significant transaction with a person that is part of, or operates for or on behalf of, the defense or intelligence sectors of the Government of the Russian Federation.”
The Department of State has published a list of individuals and entities operating in the defense or intelligence sectors. Last updated on December 19, 2018, the list currently includes 84 parties.
While “significant transaction” is considerably vague, U.S. government representatives have informally stated that they understand it to include transactions such as the acquisition of major weapons systems from Russia by third countries. The availability of CAATSA is believed to have prevented a number of foreign governments from procuring Russian military equipment.
At a minimum, inclusion on the CAATSA list should constitute a “red flag,” requiring further research and analysis before proceeding with any transaction.
The Department of Treasury, Office of Foreign Assets Control (OFAC) also operates a sanctions program based on other CAATSA sections.