Specifically, the NDAA 2020 includes the entitled "Protecting Europe’s Energy Security Act of 2019 (“the Act”)" was designed to mitigate Russia's activity in Europe's energy demands, additionally imposing restrictions to some shipping-related activities.

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In a timeframe of 60 days, the State Department is required to issue a report identifying whether any vessels have been linked in pipe-laying at depths of 100 feet or more below sea level for the construction of NordStream 2 or TurkStream pipelines (or any project that is a successor to either such project). Also, the report will also identify which foreign people (meaning non US people) have:

  1. knowingly sold, leased, or provided those vessels for the construction of such a project; or
  2. facilitated deceptive or structured transactions to provide those vessels for the construction of such a project.

If a breach is reported by the State Department, the US is able to:

  • Halt the property of all persons identified in the report to the extent that such property is or comes within the US;
  • Prohibit the entry into the US of “corporate officers” or “controlling shareholders” of persons so designated.

Concluding, OFAC has made clear that given that there will be a 30-day wind-down period

Involved parties that have knowingly sold, leased, or provided vessels that are engaged in pipe laying at depths of 100 feet or more below sea level for the construction of Nord Stream 2 or Turkstream must ensure that such vessels immediately cease construction-related activity.

Concerning sanctions against Russia, in March 2019 the US in coordination with Canada and the EU imposed sanctions to six Russian companies, including shipbuilders and marine equipment manufacturers, in response to Russia’s continued and ongoing aggression in Ukraine.