What changed between these versions
A complete substitute amendment. v2 introduces a new operative section, Section 6, which mandates the seizure and transfer of certain Russian sovereign assets held by U.S. financial institutions to the Ukraine Support Fund. Additionally, v2 refines the scope of sanctions by narrowing the list of applicable Executive Orders in Section 3(a)(1)(A) and adds a new finding in Section 2.
Overview
Extensive changes throughout the bill, primarily driven by the introduction of a major new operative section. · v2 significantly expands the bill's scope by adding a mechanism for transferring Russian assets, while also making minor refinements to existing sanctions provisions and adding further contextual findings.
v2 is effectively a different bill from v1 due to the introduction of a new Section 6, which mandates the seizure and transfer of covered Russian sovereign assets held in the United States to support Ukraine. This represents a fundamental shift in the bill's approach to financing Ukraine's defense and recovery. Minor modifications were also made to the findings section and the scope of existing sanctions, alongside a technical correction to a public law reference.
Major additions
This entirely new section, titled 'Transfer of Certain Russian Assets Held by United States Financial Institutions,' mandates the Secretary of the Treasury to seize, confiscate, transfer, or vest covered Russian resources held by U.S. financial institutions. The resulting funds are to be deposited into the Ukraine Support Fund, established under the REPO for Ukrainians Act, for purposes including the purchase of defense articles for the Government of Ukraine. It also grants the Secretary similar authorities as the President under the REPO for Ukrainians Act and includes a presidential waiver provision for up to one year under specific conditions.
This addition introduces a powerful new mechanism for directly funding Ukraine's defense and recovery efforts using seized Russian sovereign assets. It significantly expands the financial tools available to the U.S. government beyond sanctions, potentially providing a substantial and direct source of aid. This shifts the bill from purely punitive sanctions to active asset utilization for aid.
This new finding details a statement made by the President on July 14, 2025, expressing displeasure with Russian leader Vladimir Putin and Moscow's obstruction of the peace process, while also announcing new weapons deliveries for Ukraine. The President's statement emphasizes the need for 'action' and 'results' over mere 'talk'.
This addition provides updated contextual information regarding the ongoing conflict and the President's stance, reinforcing the urgency and justification for the bill's measures. It highlights the continued Russian aggression despite diplomatic efforts, strengthening the rationale for the bill's sanctions and asset transfer provisions.
Modifications
This modification narrows the scope of foreign persons whose financial service providers would be subject to sanctions under this Act. It focuses the sanctions specifically on those designated under E.O. 14024, potentially reducing the number of entities targeted compared to the broader list in v1. This means fewer foreign persons would trigger the sanctions on financial institutions that service them.
Before
v1 required sanctions against foreign financial institutions providing services to persons designated under Executive Orders 13660, 13661, 13662, 13685, or 14024.
After
v2 requires sanctions against foreign financial institutions providing services to persons designated under Executive Order 14024.
This is a technical correction that does not alter the operative impact of the sanctions. It ensures the correct legal reference is cited, maintaining the intended scope of sanctions related to CAATSA.
Before
v1 referenced Title II of the Countering America's Adversaries through Sanctions Act (Public Law 114-44).
After
v2 references Title II of the Countering America's Adversaries through Sanctions Act (Public Law 115-44).
This modification aligns the waiver provision with the narrowed scope of sanctions in Section 3(a)(1)(A). The President's waiver authority is now tied to the national emergency described in the single specified Executive Order (14024), rather than a broader set of executive orders. This does not change the core waiver mechanism but clarifies its specific reference point.
Before
v1 allowed the President to waive sanctions if it advanced the objective of resolving the national emergency described in any Executive Order listed under section 3(a)(1).
After
v2 allows the President to waive sanctions if it advanced the objective of resolving the national emergency described in the Executive Order listed under section 3(a)(1).
Scope
Fundamental restructuring — Changes are scattered throughout the bill, including an additional finding, modifications to sanctions criteria, and the introduction of an entirely new, substantive section. — v2 represents a significant change in policy direction. While v1 focused solely on sanctions to pressure Russia, v2 introduces a proactive mechanism for seizing and transferring Russian assets to directly fund Ukraine, moving beyond punitive measures to active resource utilization. — The new Section 6 introduces a distinct policy mechanism that operates in parallel to the existing sanctions framework. While it doesn't directly modify the sanctions provisions, it significantly expands the overall U.S. policy response to the conflict, interacting with the broader objective of supporting Ukraine and pressuring Russia.
Impact analysis
The Government of Ukraine
Gains direct financial support from seized Russian assets.
v2 introduces a direct mechanism for the transfer of seized Russian sovereign assets to the Ukraine Support Fund, which can be used for defense articles and other specified purposes.
The Russian Federation (Central Bank, National Wealth Fund, Ministry of Finance)
Loses sovereign assets held in the U.S. and faces increased financial pressure.
v2 mandates the seizure, confiscation, transfer, or vesting of their funds and property located in the United States.
Foreign financial institutions providing services to persons designated under Executive Orders other than 14024 (e.g., 13660, 13661, 13662, 13685)
Experiences a reduced risk of sanctions.
v2 narrows the scope of Executive Orders that trigger sanctions on these institutions. If they only service persons designated under the removed EOs, they are no longer subject to the prohibitions/conditions of Section 3(a).
United States financial institutions holding covered Russian resources
Experiences new compliance and operational requirements related to asset transfer.
v2 mandates these institutions to facilitate the seizure, confiscation, transfer, or vesting of covered Russian resources.