The U.S. Department of the Treasury ("Treasury") released a report listing senior Russian political figures and influential oligarchs. The report was prepared in accordance with the Countering America's Adversaries Through Sanctions Act ("CAATSA"). The Office of Foreign Assets Control ("OFAC") also issued an FAQ regarding the report.
Treasury asserted that inclusion on the list does not impose new sanctions on any of the individuals named, nor does it indicate that the individuals have been identified as bad actors. Many of those listed are currently subject to U.S. sanctions. The unclassified portion of the list includes 114 political figures and 96 oligarchs. According to the Treasury, there is also a classified annex to the report that includes additional Russian individuals, as well as state-affiliated companies with over $2 billion in 2016 revenue and at least 25 percent state ownership.
The Russian officials on the list include (i) senior members of the Russian Presidential Administration, (ii) members of the Russian Cabinet, Cabinet-rank ministers and heads of other major executive agencies, and (iii) other senior political leaders. The list of oligarchs includes individuals with an estimated net worth of at least $1 billion.
Commentary / James Treanor
The Treasury's list of senior political figures and oligarchs is far from revelatory. Indeed, as the department's press release states, the unclassified version of the report was crafted based on publicly available sources. Even though the contents of the list are unremarkable, its implications are intriguing. When released on the evening of January 29, the Treasury explained, reiterated and repeated that the report "does not impose sanctions on [listed] individuals and entities[,]" does not create "any other restrictions, prohibitions, or limitations on dealings with such persons[,]" and does not "indicate that the U.S. Government has information about the individual's involvement in malign activities."
Only hours later, however, Secretary of the Treasury Steven T. Mnuchin reportedly sent a different message to the Senate Banking Committee, stating "[t]here will be sanctions that come out of this report[,]" and holding out the possibility of new action within as little as a month. Thus, while the list does not itself impose new sanctions, U.S. financial institutions and other firms that engage in dealings with individuals and entities covered by the report are on notice of potential changes to come.
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