“Sanctions Bill from Hell” Targets Real Estate Deals
On February 13, 2019, Sen. Lindsay Graham (R – S.C.) introduced S.482 – the Defending American Security from Kremlin Aggression Act of 2019 (“DASKAA”), a bill intended “[t]o strengthen the North Atlantic Treaty Organization, to combat international cybercrime, and to impose additional sanctions with respect to the Russian Federation and for other purposes.” DASKAA was introduced by a bipartisan coalition of Senators and is a revision to a similar bill that was introduced but stalled in the Senate in 2018.
Like its previous iteration, dubbed by its authors as the “sanctions bill from hell,” DASKAA would implement a litany of measures meant to punish Russia for its interference in the 2016 presidential election and to combat future aggression, including the development of chemical weapons, cybercrime, election interference and, importantly for our purposes, money laundering. Russian officials have denounced the bill, referring to the proposed sanctions as “insane”, “reckless”, and amounting to “racketeering.” Whether DASKAA can reach the Senate floor, let alone achieve passage through both Houses of Congress and gain the signature of the President (whose son has observed publically that “Russians make up a pretty disproportionate cross-section of a lot of our assets”), is as uncertain as the sources of Russian money flowing through the American economy. What is clear, however, is that neither the means by which Russia seeks to interfere with, exploit and influence America and the American economy, nor legislators’ willingness to keep a light on those efforts and develop measures to counter them, are going away. One example is DASKAA’s codification and expansion of the current use of Geographic Targeting Orders (“GTOs”) to combat money laundering through real estate transactions.