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FinalRR
Ibid.
824
Ibid.; US. Treasury Department, Office of Foreign Assets Control, Directives 1 and 2 Issued Pursuant to Executive Order 13662 (Blocking Property of Additional Persons Contributing to the Situation in Ukraine July 16, 2014. Julian Borger et al., EU Announces Further Sanctions on Russia After Downing of
MH17,’’ The Guardian, July 22, 2017; European Council of the European Union, EU Restrictive Measures in Response to the Crisis in Ukraine http://www.consilium.europa.eu/en/policies/sanc- tions/ukraine-crisis (visited Jan. 4, 2018). Countering America’s Adversaries Through Sanctions Act (CAATSA), PL. 115-44, Enacted Aug. 2, 2017 (originally introduced by Senator Ben Cardin as the Counteracting Russian Hostilities Act of 2017, S. 94, Jan, 2017). Executive Order 13757, Taking Additional Steps to Address the National Emergency with Respect to Significant Malicious Cyber-Enabled Activities (Annex, Dec. 29, 2016. mented by Europe and the United States. Many of these sanctions were put in place as a consequence for Russia’s illegal annexation of Ukraine’s Crimea and its support for separatists in eastern Ukraine. Other sanctions, especially those unilaterally implemented by the United States, punish malicious actors who are engaged in cyberattacks, human rights violations, or significant acts of corruption. The EU’s sanctions require the unanimous agreement of all 28 EU member states to implement, and unanimity is required to extend the sanctions every six months.
822
The EU’s sanctions against Russia fall into three categories
1. Restrictive measures on individuals and entities in Russia and Ukraine believed to be involved in the annexation of Crimea and efforts to destabilize eastern Ukraine
2. Economic sanctions targeting Russia’s finance, defense, and energy sectors and
3. Restrictions on trade, investment, and tourism services with the occupied Crimea region.
823
In early 2014, shortly after Russia’s annexation of Crimea, US. and EU sanctions mostly focused on visa bans and asset freezes, but under pressure from the US. Congress, the Obama Administration applied additional sectoral sanctions in July After intelligence sources indicated that separatists using a Russian-sup- plied missile shot down Malaysia Airlines Flight MH17 over Ukraine, the EU also expanded its sanctions list and added sec- toral sanctions.
825
The EU has tied the removal of sanctions on Russia with the full implementation of the Minsk peace agreements for Ukraine, and appears to be committed to maintaining the sanctions until then. US. sanctions on Russia for Ukraine-related and cyber-related matters were codified into law in August 2017 with the passage (by a vote of 98-2 in the Senate and 419-3 in the House of Representatives) and signing of the Countering America’s Adversaries Through Sanctions Act of 2017, also known as CAATSA.
826
The law codified Russia-related sanctions imposed by executive orders under the Obama Administration, and the cyber-related sanctions designating both the FSB and the GRU (Russia’s military intelligence agency) as institutions threatening US. cybersecurity.
827
CAATSA enlarged the scope of the sanctions to prohibit a range of cyber-related activities conducted on behalf of the Russian government that undermine the cybersecurity of any US. or foreign per-
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147 828
CAATSA, PL. 115-44, § 224.
829
Ibid. § 231.
830
Ibid. § 233. Sergei Magnitsky Rule of Law Accountability Act, PL. 112-208, Title IV (enacted Dec. 14,
2012); The Global Magnitsky Human Rights Accountability Act, PL. 114-328, Subtitle F, Title XII (enacted Dec. 23, 2016).
832
Stratfor, Russia Won’t Sit Still for Additional US. Sanctions Dec. 28, 2017. International Monetary Fund, Russian Federation Staff Report for the 2015 Article IV Con-

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