Abstract

Despite the passage of several statutory deadlines, by February 2018 the Trump administration had imposed no Russia-related sanctions pursuant to certain provisions of the Countering America's Adversaries Through Sanctions Act (CAATSA), suggesting at one point that the threat of sanctions alone would be sufficient to deter further malfeasance. Then, on March 15, 2018, more than five months after the passage of an initial statutory deadline, the Trump administration announced that it would impose sanctions on five entities and nineteen individuals for their involvement in “malign” cyber activities on behalf of the Russian government.

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