Updated January 11 2018 Countering America’s Adversaries Through Sanctions Act CAATS Act Deadlines Time Frames and Start Dates The Countering America’s Adversaries Through Sanctions Act CAATS Act P L 115-44 signed into law August 2 2017 requires a number of actions or reports of the executive branch within a specific timeframe by a deadline or starting from a specific date The CAATS Act has three titles each dedicated to a particular U S economic sanctions regime Title I Countering Iran’s Destabilizing Activities Act of 2017 Title II Countering Russian Influence in Europe and Eurasia Act of 2017 and Title III Korean Interdiction and Modernization of Sanctions Act The act also creates new authorities or amends existing authorities for the President to impose economic sanctions at his discretion or based on his determinations and certifications see CRS In Focus IF10694 Countering America’s Adversaries Through Sanctions Act Action Due By September 1 2017 30 days  Section 225 – Requires President on or after this date to impose Ukraine Freedom Support Act UFSA defined sanctions on any “foreign person who knowingly makes a significant investment in a special Russian crude oil project ” unless he determines that it is not in the national interest previously discretionary  Section 226 2 – Requires President on or after this date to impose restrictions on any foreign financial institution that facilitates transactions for any Russian Specially Designated National SDN unless he determines that it is not in the national interest previously discretionary Action Due By October 1 2017 60 days  Section 223 – Modify Directives 1 and 2 to Executive Order 13662 pertaining to length of maturity for certain short-term debt targeting Russia entities for Ukrainerelated activities Secretary of the Treasury  Section 224 – Requires President on or after this date to issue sanctions—based on International Emergency Economic Powers Act IEEPA authorities or defined in Section 235 of the Act or Section 4 of the UFSA— targeting Russia’s illicit cyber activities  Section 231 – President issues regulations or other guidance to define “persons that are part of or operate for or on behalf of the defense and intelligence sectors” of the Russian government in anticipation of sanctions required at 180 days January 29 2018 Action Due By October 31 2017 90 days  Section 105 – President imposes IEEPA-based sanctions on Iran Revolutionary Guard Corps IRGC and foreign persons that are IRGC affiliates officials or agents  Section 106 a – State Department identifies persons responsible for extrajudicial killings torture other human rights violations against Iranian whistleblowers human rights defenders or their supporters annually thereafter  Section 110 – Report on U S citizens held by Iran or groups supported by Iran and U S efforts to secure their release President unclassified classified every 180 days thereafter  Section 223 – Modify Directive 4 to Executive Order 13662 affecting exports allowed for oil exploration in Russia Secretary of the Treasury  Section 255 – Report on media organizations controlled or owned by Russian government President unclassified classified ends August 2 2022  Section 256 – Report on funds provided by Russian Russia to influence elections in Europe or Eurasia President unclassified classified ends August 2 2022  Section 324 –Secretary of State reports on “whether North Korea meets the criteria for designation as a state sponsor of terrorism” unclassified classified Action Due By January 29 2018 180 days minus 10 days  Section 333 – President notifies Congress not fewer than 10 days prior to issuing regulations to implement the North Korea title Action Due By January 29 2018 180 days  Section 103 – Regional strategy for deterring conventional and asymmetric Iranian activities and threats State Defense the Treasury Director of National Intelligence DNI unclassified classified every two years thereafter  Section 104 – Report on persons contributing to Iran’s ballistic missile program in previous 180 days President unclassified classified every 180 days thereafter  Section 109 – Report on US-EU coordination on Iranrelated sanctions over previous 180 days President unclassified classified every 180 days thereafter  Section 231 – President on and after this date imposes Section 235 sanctions on those engaging in a significant transaction with a person who is part of or operates for or on behalf of Russia’s defense or intelligence sector President may waive application with certification every 180 days “that the person is substantially reducing the number of significant transactions ” https crsreports congress gov Countering America’s Adversaries Through Sanctions Act CAATS Act Deadlines Time Frames and Start Dates  Section 241 – Report on Russian oligarchs and parastatals U S economic exposure to such persons effects of restrictions on debt and equity potential impact of secondary sanctions Secretary of the Treasury with State DNI unclassified classified  Section 242 – Report on expanding Russian sanctions to include sovereign debt and derivative products Secretary of the Treasury with State DNI unclassified classified  Section 257 – Report on assisting Ukraine in its energy crisis in Ukraine provided in Section 7 c of UFSA with specific reporting on emergency energy assistance funding Secretary of State every 180 days thereafter congressional briefings 30 days after report ends August 2 2022  Section 273 – Report on Treasury’s financial attachés and technical assistance advisors in U S embassies— their work on terrorist financing money laundering proliferation financing Secretary of the Treasury  Section 311 – President reports on whether there are “reasonable grounds” to designate six specific entities individuals and their affiliates as SDN for their North Korea activities as defined in the North Korea Sanctions and Policy Enhancement Act of 2016 NKSPEA P L 114-122 unclassified classified  Section 313 amending §203 NKSPEA – Report on compliance of foreign countries to curtail arms trafficking involving North Korea Secretary of State unclassified classified annually thereafter for five years  Section 314 amending §205 NKSPEA – Report on foreign sea ports and airports that fail to implement U N Security Council resolutions UNSCR relating to inspection of cargo to from North Korea with details on specific ports in China Iran Russia and Syria President unclassified classified annually thereafter for five years  Section 315 amending the Ports and Waterways Safety Act at 33 U S C 1232c – Report identifying foreign vessels over 300 gross tons owned or operated by or on behalf of the government of North Korea or a DPRK person an entity identified by the Section 205 NKSPEA report or a foreign government that does not comply with relevant UNSCR Secretary overseeing Coast Guard published with periodic updates  Section 316 – President reports on North Korea-Iran cooperation on ballistic missiles chemical or biological weapons or conventional weapons programs including names of other foreign nationals that facilitate this cooperation and the relationship to UNSCR requirements unclassified classified annually thereafter for five years  Section 317 – President reports on others’ efforts to comply with DPRK-related UNSCR unclassified classified annually thereafter for five years  Section 318 – President briefs on international use of specialized financial messaging services available to DPRK financial institutions may be classified every 180 days thereafter for five years  Section 333 – Regulations to implement the North Korea title Not fewer than 10 days prior to issuing the regulations President shall notify and provide the proposed regulations to the appropriate congressional committees Action Due By April 1 2018 explicit in legislation  Section 254 – Report on programs and activities carried out under the Countering Russian Influence Fund Report on funding provided to certain countries by the European Union EU and NATO countries and international organizations and “quasi-governmental funding entities” Secretary of State through Coordinator of U S Assistance to Europe and Eurasia every April 1 thereafter terminates August 2 2022 Action Due By April 29 2018 270 days  Section 271 – Report on pilot project for Somali money transfers addressing cross-border fund transfers and other tools used in illicit finance activities Secretary of the Treasury Action Due By August 2 2018 one year  Section 243 – Report on illicit finance e g terrorism narcotics proliferation money laundering relating to Russia Secretary of the Treasury with Attorney General DNI Homeland Security State unclassified classified annually through 2021  Section 261 – Strategy for combatting terrorism financing and related forms of illicit finance President through the Secretary of the Treasury with Attorney General State Homeland Security DNI Office of Management and Budget and Federal financing agencies and regulators unclassified classified updates January 31 2020 January 31 2022 Action Due By January 31 2020  Section 261 – First update of national strategy for combatting the financing of terrorism and related forms of illicit finance see August 2 2018 Action Due By January 31 2022  Section 261 – Second update of national strategy for combatting the financing of terrorism and related forms of illicit finance see August 2 2018 Action Due By August 2 2022 five years  Section 108 – Review of Iran-related designations on the Department of the Treasury’s Office of Foreign Assets Control OFAC SDN list to determine role in Iran’s international terrorism or ballistic missile program and apply appropriate sanctions President Dianne E Rennack Specialist in Foreign Policy Legislation IF10805 https crsreports congress gov Countering America’s Adversaries Through Sanctions Act CAATS Act Deadlines Time Frames and Start Dates Disclaimer This document was prepared by the Congressional Research Service CRS CRS serves as nonpartisan shared staff to congressional committees and Members of Congress It operates solely at the behest of and under the direction of Congress Information in a CRS Report should not be relied upon for purposes other than public understanding of information that has been provided by CRS to Members of Congress in connection with CRS’s institutional role CRS Reports as a work of the United States Government are not subject to copyright protection in the United States Any CRS Report may be reproduced and distributed in its entirety without permission from CRS However as a CRS Report may include copyrighted images or material from a third party you may need to obtain the permission of the copyright holder if you wish to copy or otherwise use copyrighted material https crsreports congress gov IF10805 · VERSION 3 · UPDATED