CAATSA (the Countering America’s Adversaries Through Sanctions Act) passed in 2016 modified two Ukraine-related laws, UFSA & SSIDES. UFSA’s secondary sanctions on foreign financial institutions (FFI) that deal with Russia program SDNs under EOs 13660-13662 and future EOs were made mandatory, while CAATSA added a whole new sanction that levied mandatory sanctions on persons under IEEPA authorities.
Mr. Watchlist wrote about this here on one of our partner’s blogs… hope you find it interesting.
