This is a particularly powerful enforcement mechanism against threatened Russian expropriation6 — and may allow for speedy recovery of judgments, in particular because billions of dollars are sitting frozen in United States banks.\1 The United States has the legal authority to make such designations under 50 U.S.C 481, National Defense Authorization Act for Fiscal Year 2019, Section 1754(c); 22 U.S.C. 2780, Arms Export Control Act, Section 40; and 22 U.S.C. 2371, Foreign Assistance Act of 1961, Section 620A.2 State Sponsors of Terrorism, U.S. Dep’t. of State, https://www.state.gov/state-sponsors-of-terrorism/.3See id.4 Terrorism Risk Insurance Act, H.R. 3210, Pub. Law 107-297, https://www.congress.gov/bill/107th-congress/house-bill/3210.5Stansell v. Revolutionary Armed Forces of Columbia, 771 F.3d 713, 722-23 (11th Cir. 2014).6 For a discussion on the potential use of international investment treaties and their arbitration provisions to combat potential expropriation of foreign investments in Russia, see International Arbitration under International Treaties: A Potential Remedy to Putin’s Threats of Expropriation.[View source.]

y taken in violation of international law is at issue; Rights in property in the United States acquired by succession or gift or rights in immovable property situated in the United States are at issue; Money damages are sought against a foreign state for personal injury or death, or damage to or loss of property, occurring in the United States and caused by the tortious act or omission of that foreign state; Action brought to enforce an agreement made by the foreign state with or for the benefit of a private party to submit to arbitration; Money damages are sought against a foreign state for personal injury or death that was caused by an act of torture, extrajudicial killing, aircraft sabotage, hostage taking, or the provision of material support or resources for such an act, if the foreign state is designated as a state sponsor of terrorism under section 6(j) of the Export Administration Act of 1979 (50 U.S.C. App 2405(j) or Section 620A of the Foreign Assistance Act of 1961 (22 U.S.C. 2371). A suit in admiralty is brought to enforce a maritime lien against a vessel or cargo of the foreign state which maritime lien is based upon a commercial activity of the foreign state.

y taken in violation of international law is at issue; Rights in property in the United States acquired by succession or gift or rights in immovable property situated in the United States are at issue; Money damages are sought against a foreign state for personal injury or death, or damage to or loss of property, occurring in the United States and caused by the tortious act or omission of that foreign state; Action brought to enforce an agreement made by the foreign state with or for the benefit of a private party to submit to arbitration; Money damages are sought against a foreign state for personal injury or death that was caused by an act of torture, extrajudicial killing, aircraft sabotage, hostage taking, or the provision of material support or resources for such an act, if the foreign state is designated as a state sponsor of terrorism under section 6(j) of the Export Administration Act of 1979 (50 U.S.C. App 2405(j) or Section 620A of the Foreign Assistance Act of 1961 (22 U.S.C. 2371). A suit in admiralty is brought to enforce a maritime lien against a vessel or cargo of the foreign state which maritime lien is based upon a commercial activity of the foreign state.

in violation of international law is at issue; Rights in property in the United States acquired by succession or gift or rights in immovable property situated in the United States are at issue; Money damages are sought against a foreign state for personal injury or death, or damage to or loss of property, occurring in the United States and caused by the tortious act or omission of that foreign state; Action brought to enforce an agreement made by the foreign state with or for the benefit of a private party to submit to arbitration; Money damages are sought against a foreign state for personal injury or death that was caused by an act of torture, extrajudicial killing, aircraft sabotage, hostage taking, or the provision of material support or resources for such an act, if the foreign state is designated as a state sponsor of terrorism under section 6(j) of the Export Administration Act of 1979 (50 U.S.C. App 2405(j) or Section 620A of the Foreign Assistance Act of 1961 (22 U.S.C. 2371). A suit in admiralty is brought to enforce a maritime lien against a vessel or cargo of the foreign state which maritime lien is based upon a commercial activity of the foreign state.

y taken in violation of international law is at issue; Rights in property in the United States acquired by succession or gift or rights in immovable property situated in the United States are at issue; Money damages are sought against a foreign state for personal injury or death, or damage to or loss of property, occurring in the United States and caused by the tortious act or omission of that foreign state; Action brought to enforce an agreement made by the foreign state with or for the benefit of a private party to submit to arbitration; Money damages are sought against a foreign state for personal injury or death that was caused by an act of torture, extrajudicial killing, aircraft sabotage, hostage taking, or the provision of material support or resources for such an act, if the foreign state is designated as a state sponsor of terrorism under section 6(j) of the Export Administration Act of 1979 (50 U.S.C. App 2405(j) or Section 620A of the Foreign Assistance Act of 1961 (22 U.S.C. 2371). A suit in admiralty is brought to enforce a maritime lien against a vessel or cargo of the foreign state which maritime lien is based upon a commercial activity of the foreign state.

in violation of international law is at issue; Rights in property in the United States acquired by succession or gift or rights in immovable property situated in the United States are at issue; Money damages are sought against a foreign state for personal injury or death, or damage to or loss of property, occurring in the United States and caused by the tortious act or omission of that foreign state; Action brought to enforce an agreement made by the foreign state with or for the benefit of a private party to submit to arbitration; Money damages are sought against a foreign state for personal injury or death that was caused by an act of torture, extrajudicial killing, aircraft sabotage, hostage taking, or the provision of material support or resources for such an act, if the foreign state is designated as a state sponsor of terrorism under section 6(j) of the Export Administration Act of 1979 (50 U.S.C. App 2405(j) or Section 620A of the Foreign Assistance Act of 1961 (22 U.S.C. 2371). A suit in admiralty is brought to enforce a maritime lien against a vessel or cargo of the foreign state which maritime lien is based upon a commercial activity of the foreign state.