A “CAATSA waiver” is not one universal permission to ignore sanctions. It refers to a section-specific legal mechanism, and the applicable decision-maker, test, notice requirements, and effect depend on the provision involved. One concrete example is the waiver authority in 22 U.S.C. § 8928(c); that rule should not be assumed to govern every sanction under the Countering America’s Adversaries Through Sanctions Act (CAATSA).
What does a CAATSA waiver mean?
CAATSA is a multi-title U.S. sanctions law concerning Iran, Russia, and North Korea. The Treasury Department’s Office of Foreign Assets Control (OFAC) organizes related materials under different titles and cautions that similar language can be interpreted differently because the titles address different foreign-policy and national-security objectives. Start by identifying the exact section, rather than treating “the CAATSA waiver” as a single program-wide exemption. OFAC’s CAATSA-related sanctions page links to program materials and statutory sources.
In general, a waiver is authority to set aside specified sanctions in circumstances allowed by the relevant law. It does not automatically erase the underlying statute, remove sanctions for everyone, or establish that a person has met the conditions for a different form of relief. The scope and effect have to be read from the particular provision and the actual waiver action, if one exists.
One specific example: the waiver in 22 U.S.C. § 8928(c)
Section 8928 is part of the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act, as amended by CAATSA. Under subsection (c), the President may waive the application of sanctions under that section with respect to a person if the President determines that the waiver is in the U.S. national-security interests and submits notice and a justification to specified Senate and House committees on or before the waiver takes effect. Read the statutory text in Title 22 of the U.S. Code for the provision’s precise scope and requirements.
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That is a rule for sanctions under § 8928, not a default test for all CAATSA sections. Do not infer that another provision uses the same decision-maker, national-security standard, congressional notice, or timing unless its own text and implementing materials say so.
Waiver is not termination
Section 8928 separately provides for termination under different conditions. The termination notice must state that the person is no longer engaging in the conduct that was the basis for sanctions, or has taken significant verifiable steps toward stopping it, and has provided reliable assurances that the person will not knowingly engage in sanctionable activity in the future. A waiver and a termination therefore describe distinct legal routes, with different stated conditions.
“Suspension,” “license,” “exception,” “waiver,” and “termination” are not interchangeable labels. A license or other authorization may have its own legal basis and scope; a waiver should be identified by the specific statute or official action that authorizes it.
How Sections 231 and 232 differ
Sections 231 and 232 are often discussed in connection with Russia, but they address different conduct. The available agency materials describe their subject matter and implementation differently; they do not establish one general waiver test that applies to both.
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| Provision | Conduct or activity described | What the cited material establishes about discretion or waiver |
|---|---|---|
| Section 231 | Significant transactions involving persons identified as part of, or operating for or on behalf of, Russia’s defense or intelligence sectors. | The State Department says the President delegated implementation authority to the Secretary of State, in consultation with the Secretary of the Treasury. The cited page does not establish a general waiver test or that Turkey received a waiver. |
| Section 232 | Certain investments and provision of goods or services that directly and significantly facilitate Russian energy-export pipeline projects. | State Department guidance describes Section 232 sanctions as discretionary and discusses implementation thresholds and timing. That discretion is not a general waiver standard for other CAATSA provisions. |
| 22 U.S.C. § 8928(c) | Application of sanctions under § 8928 with respect to a person. | The statutory text provides a national-security-interest determination and congressional notice with justification on or before the waiver takes effect. This is a section-specific rule. |
For Section 231, consult the State Department’s Section 231 page. For Section 232, consult the department’s Section 232 public guidance. The guidance’s discussion of implementation or discretion should not be imported into a different provision without checking that provision’s law and rules.
Did Turkey receive a CAATSA waiver?
The State Department’s Section 231 page records sanctions imposed on Turkey on December 14, 2020 under CAATSA Section 231. That is evidence of a sanctions action, not evidence that Turkey received a waiver. The cited material does not establish a Turkish waiver, so the sanctions announcement should not be described as one.
Congressional debate on August 1, 2018 discussed the foreign-policy trade-offs and expedited review process associated with waiver authority, including concerns about effects on U.S. arms sales and defense relationships. That record is useful policy context, but debate summaries are not a substitute for the enacted statutory text or an official waiver determination. See the Congressional Record for August 1, 2018.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How to check whether a particular waiver exists
- Identify the exact section. Find the statutory provision associated with the person, transaction, or sanctions announcement. A reference to CAATSA alone is not enough to determine the applicable rule.
- Read that provision’s text. Check who may make the decision, the substantive conditions, the required notice or certification, when it must occur, and which sanctions can be affected.
- Check the implementing agency record. Use current Treasury and State Department program pages, regulations, guidance, and official announcements. OFAC’s CAATSA-related sanctions index links to program-specific resources; the page lists recent actions dated February 24, 2026, November 19, 2025, and July 1, 2025.
- Locate the waiver-specific action. Look for the actual notice, determination, or other instrument and read its scope, effective date, conditions, and duration. A sanctions announcement, diplomatic statement, or press report alone does not prove that a waiver was granted.
- Check for later changes. Confirm the current agency record and any subsequent notice before relying on an older action. An index of program resources is not a complete consolidated inventory of all waivers.
The statutory and agency materials cited here do not provide a complete inventory of waivers under every CAATSA section, with each waiver’s terms, duration, and congressional notifications. A claim about a particular person or transaction requires the relevant section and its official action record.
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