National Defense Authorization Act – Implications for U.S. Sanctions Programs

Vitalii Vodolazskyi | Shutterstock

The NDAA impacts a wide range of national security concerns and may have important long-term implications for multiple sanctions programs. However, its overall impact on U.S. sanctions is relatively minor – especially when compared to all of the proposed amendments that could have made their way into the final bill.

Indeed, the NDAA’s passage through the Senate was forestalled by a number of Senators trying to maneuver their respective sanctions-related amendments into the bill. For example, Sen. Jim Risch (R-ID) attempted to secure an amendment on Nord Stream 2 sanctions, and Sen. Marco Rubio (R-FL) unsuccessfully tried to add sanctions language from the Uyghur Forced Labor Prevention Act to the text of the NDAA. While the impact of the final version of the NDAA is less than what it could have been vis-à-vis sanctions, there are still important considerations to be aware of.