marred implementation, but, as will be shown below, there is significant leeway for the imposition of sanctions.

Section 231 of CAATSA legally mandates the imposition of sanctions to any person, US or non-US, who engages in a “significant transaction” with “a person that is part of, or operates for or on behalf of, the defense or intelligence sectors of the Government of the Russian Federation, including the Main Intelligence Agency of the General Staff of the Armed Forces of the Russian Federation or the Federal Security Service of the Russian Federation.” The State Department has targeted 33 Russian defense companies and six intelligence entities for the purposes of Section 231 with flexibility to designate more.

The list includes entities, mostly state-owned, which manage and generate significant financial flows within Russianbetween the two companies)

Russian Helicopters JSC (in 2016, this company, which is part of Rostec, produced 32 per cent of the global helicopter fleet and 22 per cent of the global military fleet)

United Shipbuilding Corporation (the largest shipbuilding company in Russia, accounting for 80 per cent of the domestic shipbuilding industry)

United Aircraft Corporation (which holds the rights for brands such as MiG, Tupolev, Ilyushin, Sukhoi, SSJ 100 and MS-21).

The country’s internal security and counterintelligence service – the Federal Security Service (FSB), the external intelligence agency – the Foreign Intelligence Service (SVR), and the Russian military intelligence service – the Main Intelligence Directorate of the General Staff of the Russian Armed Forces (GRU) are among the intelligence entities targeted by the list. However, the 33 Russian defense companies and