Trump Russia SactionsPresident Trump signed new legislation last week imposing new sanctions on Russia, Iran and North Korea, which could have implications for the equipment manufacturing industry.

Provisions targeting Russia’s domestic energy sector are of particular relevance to the equipment manufacturing industry. The law expands President Trump’s discretionary authority to impose sanctions on state-owned entities in the railway, metal and mining sector. The president has the authority to impose, in coordination with “allies of the United States,” sanctions on anyone who makes an investment of $1 million or more or $5 million or more over a 12-month period in the construction of Russian energy export pipelines or sells goods, services, technology, information or support for their construction, modernization or repair.

The law also requires the president to impose sanctions against a foreign person who “knowingly makes a significant investment in a special Russian crude oil project” within 30 days of the law’s enactment, unless the president “determines that it is not in the national interest of the United States.”

While imposing these new sanctions, the law also limits President Trump (or any future president’s) ability to unilaterally lift these sanctions without a period of review by Congress, which has the option to vote to disapprove any lifted sanction.

The new law – the Countering America’s Adversaries Through Sanctions Act – passed both the House and Senate by overwhelmingly bipartisan margins, but is ensnared by the broader political conversation about Russian involvement in the 2016 election. President Trump issued a statement when signing the sanctions bill into law questioning the constitutionality of congressional review as envisioned by the law.

AEM is currently reviewing the numerous provisions contained in the law and will be seeking further clarification from the U.S. government in the implementing regulations. For more information, please contact AEM’s Alex Russ (, tel: 202-898-906).