On December 20, 2019, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2020, which, in a title named "Protecting Europe's Energy Security Act of 2019" (PEESA), authorizes imposition of sanctions against persons involved in the Nord Stream 2 and Turkstream pipeline projects.
PEESA requires the Secretary of State, in consultation with the Secretary of Treasury, to issue a report to Congress by February 18, 2020 identifying:
Additional such reports are required for each succeeding 90-day period thereafter.
Non-US persons identified in the reports, and corporate officers and principal shareholders of entities so identified, are – with immediate effect – ineligible to enter the US. Moreover, the President is required to block and prohibit transactions concerning property and interests in property of persons identified in the reports, which is likely to result in their inclusion on the US list of Specially Designated Nationals.
The sanctions will not be imposed, however, upon persons certified by the President to have, not later than 30 days after enactment of the PEESA (i.e., by January 19, 2020), engaged in good faith efforts to wind down operations that would otherwise call for imposition of sanctions under the PEESA. Entities that wish to obtain such certification should thus ensure that their wind-down efforts begin in earnest no later than January 19, 2020.
There are certain exceptions in the PEESA, which apply to:
Finally, the PEESA provides the President with authority to waive application of such sanctions upon determining that doing so is in the national security interests of the US.