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Financial Services Law Insights and Observations

Treasury releases list of Russian senior foreign political figures and oligarchs, does not impose new sanctions

Financial Crimes Department of Treasury Sanctions International CAATSA OFAC Russia

Financial Crimes

On January 29, the U.S. Treasury Department released an unclassified report to Congress containing a list of 210 individuals who are either senior foreign political figures in the Russian Federation or Russian oligarchs with a net worth of at least $1 billion. Treasury emphasized that the report—which was mandated through Section 241 of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA)— (i) is not a sanctions list; (ii) should not be interpreted as a determination that individuals or entities included in the report or listed within classified appendices or annexes meet the criteria for sanctions designation (individuals and entities subject to separate sanctions are denoted within the report); and (iii) does not serve to indicate that the U.S. Government possesses information about an “individual’s involvement in malign activities.” Classified lists that may include officials and oligarchs of lesser rank and wealth will be submitted as well. Additionally, Treasury submitted to Congress a required classified annex to the report, which lists Russian parastatals entities that are defined as “companies in which state ownership is at least 25 percent and that had 2016 revenues of approximately $2 billion or more.” The annex also presents an analysis of potential impact on the U.S. economy that may result should additional debt and equity restrictions or sanctions be imposed on the identified entities.

Separately, on January 30, Treasury released updated FAQs to address questions related to the report’s release.

See here for additional CAATSA InfoBytes coverage.