Letter to the Hon. Janet Yellen, Secretary of the Treasury - Sen. Cramer, Banking Republicans to Oppose Treasury Nominees Over Nord Stream 2

Letter

Dear Secretary Yellen:

The Nord Stream II natural gas pipeline directly harms the national security interests of the
United States and our allies and partners. If completed, this project will increase Vladimir Putin's
malign influence over Europe, destabilize Ukraine's fragile security, and encourage further
Russian aggression. That is why the United States, during both the Obama and Trump
administrations, has strongly opposed Nord Stream II. Opposition has also been broad and
bipartisan in Congress.

Unfortunately, President Biden has unwisely reversed longstanding U.S. policy on Nord Stream
II. In May 2021, after the State Department adhered to the requirements of the Protecting
Europe's Energy Security Act (PEESA) by sanctioning Nord Stream II AG (NS2AG), the project
company established to plan and build the pipeline, Secretary Blinken unjustifiably waived that
sanction. His decision, while legal, overrode the judgement of his own State Department, which
sanctioned NS2AG because it "knowingly facilitated deceptive or structured transactions to
provide . . . vessels for the construction of [the Nord Stream II pipeline]."

However, PEESA is not the only law that requires sanctions on NS2AG. Section 228 of the
Countering America's Adversaries Through Sanctions Act (CAATSA), which passed Congress
with near unanimous support, requires the president to sanction any foreign entity that knowingly
facilitates a significant transaction for, or on behalf of, any person that is already under Russiarelated sanctions. The State Department's own PEESA findings to Congress, combined with
NS2AG's apparent ongoing involvement with sanctioned Russian entities, strongly suggests
there is evidence that NS2AG has facilitated significant transactions for, or on behalf of, one or
more previously-sanctioned entities.

For example, the sanctioned Russian-energy company Gazprom wholly owns NS2AG and the
Nord Stream II pipeline. The sanctioned Russian pipe-laying vessel Fortuna
appears to continue its work on the pipeline's construction. The sanctioned Russian ship-operator LLC Koksokhimtrans6 was reportedly brought into the Nord Stream II project for the sole purpose of evading U.S. sanctions. The CEO of the aforementioned Russian shipper is allegedly the sanctioned Russian Loginov Ilya Alekseevich. The sanctioned Russian shipping company CJSC Sovmortrans, itself a part of the sanctioned Russian shipping conglomerate SovfrachtSovmortrans Group, appears to have set up the Nord Stream II ship-operator LLC
Mortransservice. And according to an alleged Ukrainian intelligence assessment, LLC
Mortransservice received the pipe-laying vessel Akademik Cherskiy from the sanctioned Russian
Gazprom subsidiary, Gazprom Flot. Yet, the Biden administration has failed to comply with
Section 228 of CAATSA by foregoing sanctions on NS2AG.

Until the administration complies with Section 228 of CAATSA, or adequately addresses the
absence of penalties on NS2AG, we intend to oppose Department of the Treasury (Treasury)
nominees Brian Nelson and Elizabeth Rosenberg should a markup be scheduled for them at the
Senate Committee on Banking, Housing, and Urban Affairs. As you know, Mr. Nelson and Ms.
Rosenberg have been nominated for senior Treasury positions responsible for overseeing
sanctions implementation.

We urge you to reverse course on Nord Stream II and join us in Congress' long-standing defense
of European allies and partners from malign Russian aggression. Thank you for considering this
urgent national security matter

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