What It Is
The Countering America's Adversaries Through Sanctions Act (CAATSA) is a 2017 US law codifying sanctions against Russia, Iran, and North Korea. CAATSA was signed by President Trump in August 2017 with -proof congressional supermajorities — a remarkable political signal that Congress would not permit unilateral executive lifting of these .
The law codified existing executive-order sanctions on Russia (making them harder to lift unilaterally), imposed new sanctions on Iran's missile and human rights conduct, and tightened North Korea sanctions. The codification element is the most consequential feature: by writing the sanctions into statute, Congress prevented the president from lifting them through executive action alone.
Why It Matters
CAATSA's significance lies in its structural design. Most prior US sanctions regimes were created by , meaning a subsequent administration could lift them through the same instrument. CAATSA wrote Russia sanctions into law, requiring affirmative congressional approval for substantive relief.
This matters enormously for the politics of sanctions relief. A US administration that wanted to lift Russia sanctions would need:
- A bill passing both houses.
- Withstanding a likely Senate .
- Avoiding a veto by a future president if the lifting came under a different administration.
The political cost of any sanctions relief is therefore significantly higher than under pre-CAATSA executive sanctions.
Section 231 and Secondary Sanctions
Section 231 of CAATSA created exposure for foreign actors transacting with Russia's defense and intelligence sectors. The provision is potent: any non-US person or company doing significant business with Russian defense or intelligence entities can be sanctioned by the US.
Section 231 was used controversially against Turkey for purchasing the Russian S-400 air defense system. The US sanctioned Turkey's Presidency of Defense Industries in December 2020, and Turkey was removed from the F-35 program. The case demonstrated that even allies could face CAATSA penalties.
Section 235 and Sanctionable Activities
Section 235 lays out the 12 categories of sanctionable activities under CAATSA's Russia regime, including:
- Significant transactions with Russian military and intelligence.
- Significant investments in Russian energy export pipelines.
- Significant transactions facilitating financial transfers for Russian intelligence.
- Significant arms transactions with Russian state-owned arms producers.
The categories are deliberately broad and give the executive significant interpretive flexibility, while the codification limits how completely sanctions can be lifted.
Common Misconceptions
CAATSA is sometimes assumed to have been weakened by political shifts. The codification has held despite multiple administrations of different political orientation. The structural protection Congress built into the law has been remarkably durable.
Another misconception is that CAATSA's secondary sanctions are uniformly enforced. In practice, secondary sanctions enforcement under Section 231 has been selective — the Turkey case is unusual; many other potential cases (India's S-400 purchase, various third-country deals) have been navigated through waivers and diplomatic management rather than formal sanctions.
Real-World Examples
The December 2020 Turkey CAATSA sanctions were the most prominent Section 231 enforcement action. India's 2018 S-400 purchase has been a long-running CAATSA issue managed through bilateral diplomatic processes; India has not been sanctioned but the threat is structural.
The 2022–26 escalation of Russia sanctions in response to the Ukraine invasion has built on CAATSA's codified base. New executive-order sanctions have been layered on top of the CAATSA structure, creating a dense and difficult-to-unwind regime.
Example
Under CAATSA Section 231, the US sanctioned Turkey's Presidency of Defense Industries (SSB) in December 2020 for its S-400 acquisition — applying secondary sanctions to a NATO ally.