Last Friday the State Department belatedly released a list of 39 Russian entities that operate as part of Russia’s defense and intelligence sectors (the full list is below). Congress required the Trump Administration to produce a list of such parties as part of the Countering America’s Adversaries Through Sanctions Act (CAATSA), which became law in August 2017. Under Section 231 of CAATSA, persons that engage in “significant” transactions with the designated firms could be subject to a menu of secondary sanctions starting on January 29, 2018.

According to State Department guidance, whether a transaction is “significant” will depend on a number of factors, including the significance of the transaction to U.S. national security and foreign policy interests, the nature and magnitude of the transaction, and the relation and significance of the transaction to the Russian defense or intelligence sector. During the initial phase of implementation, enforcement will apparently focus on parties that conduct transactions of a “defense or intelligence” nature with the listed firms. For now the State Department does not expect to sanction parties that conduct transactions related to goods or services with purely civilian end uses and/or end users that do not relate the Russian intelligence sector.

Secondary sanction penalties could include restrictions on accessing the U.S. financial system, seizure and blocking of a sanctioned party’s property, barring the entry of corporate officers to the United States, sanctions on principal executive officers, U.S. government procurement restrictions, and export licensing restrictions, among other penalties.

List regarding the Russian defense sector:

Admiralty Shipyard JSC
Almaz-Antey Air and Space Defense Corporation JSC
Dolgoprudny Research Production JSC
Federal Research and Production Center Titan Barrikady JSC (Titan Design Bureau)
Izhevsk Mechanical Plant (Baikal)
Izhmash Concern JSC
Kalashnikov Concern JSC
Kalinin Machine Building Plant JSC (KMZ)
KBP Instrument Design Bureau
MIC NPO Mashinostroyenia
Molot Oruzhie
Mytishchinski Mashinostroitelny Zavod
Novator Experimental Design Bureau
NPO High Precision Systems JSC
NPO Splav JSC
Oboronprom OJSC
Radio-Electronic Technologies (KRET)
Radiotechnical and Information Systems (RTI) Concern
Research and Production Corporation Uralvagonzavod JSC
Rosoboronexport OJSC (ROE)
Rostec (Russian Technologies State Corporation)
Russian Aircraft Corporation MiG
Russian Helicopters JSC
Sozvezdie Concern JSC
State Research and Production Enterprise Bazalt JSC
Sukhoi Aviation JSC
Tactical Missiles Corporation JSC
Tikhomirov Scientific Research Institute JSC
Tupolev JSC
United Aircraft Corporation
United Engine Corporation
United Instrument Manufacturing Corporation
United Shipbuilding Corporation

List regarding the Russian intelligence sector:

Autonomous Noncommercial Professional Organization/Professional Association of Designers of Data Processing (ANO PO KSI)
Federal Security Service (FSB)
Foreign Intelligence Service (SVR)
Main Intelligence Directorate of the General Staff of the Russian Armed Forces (GRU)
Special Technology Center
Zorsecurity

Secondary Sanctions Targeting Russia’s Defense and Intelligence Sectors Move Closer to Implementation