State Department Updates Guidance for European Pipeline Sanctions

The State Department issued updated guidance on its implementation of the amended Protecting Europe's Energy Security Act, which requires the agency to report to Congress and potentially sanction foreign people or entities involved in Nord Stream 2, TurkStream and other gas pipeline projects. The April 9 guidance outlines the “range of activities captured under” the legislation and describes the various sanctions exceptions in the bill, including exceptions for activities that “are intended for the safety and care of the crew aboard the vessel” and that are meant to avoid harming the environment. The guidance also explains the bill’s wind-down provision for people and entities that are subject to sanctions.