With NDAA 2021 now becoming a law, additional sanctions related to Nord Stream 2 enter into force. The law triggers 30-day period for non-US persons to wind down participation in the project. /1

Foreign entities providing insurance for the pipe-laying vessels and testing/inspection/certification of the pipeline are expected to walk away. @business reported primary insurer for NS2 was Zurich Insurance Group. Certification of the pipeline is to be made by DNV GL. /2

DNV GL has said it complies with sanctions regimes and actually complied with previous legislation after @StateDept expanded interpretation of it. Consultations with government of Norway required by NDAA won’t help, and DNV’s refusal to certify the pipeline seems inevitable. /3

NS2 pipeline has been designed in accordance with DNV OS F101 standard, and it’s not clear if the verifying party can be replaced. There is Russian national standard identical to that of DNV, but will it conform to “third party” requirement stated in the Danish permit? /4

Receiving a certificate of compliance won’t be enough for Nord Stream 2, with annual inspections after commissioning also required (in accordance with DNV rules). NDAA 2021 targets entities providing inspection services necessary for “completion or operation” of the pipeline. /5

Finally, if Fortuna pipelayer is accompanied by Murman and Baltic Explorer supply vessels (as notified by NS2 to Denmark), their owner, Russia’s Marine Rescue Service, would be exposed to sanctions risk too. The ships may be deemed to “facilitate providing” pipe-laying vessels /6