Pursuant to section 241(a)(1) of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA), the US Treasury has published an unclassified Report, listing 114 ‘senior foreign political figures’ and 96 ‘oligarchs’ in the Russian Federation, determined by their “closeness to the Russian regime and their net worth”. The Report makes clear that “it is not a sanctions list”; while some people mentioned may have been sanctioned pursuant to other authorities, inclusion of individuals or entities in the Report should not be interpreted as imposing sanctions on them (OFAC FAQ reiterates this point).
The 114-long list of ‘senior foreign political figures’ consists of (inter alia) senior members of the Russian Presidential Administration, members of the Russian Cabinet, and other senior political leaders, including the leadership of the State Duma and Federation Council, members of the Russian Security Council, and senior executives at state-owned enterprises (individuals listed in Appendix A to the Report). The 96-long list of ‘oligarchs’ in the Russian Federation consists of those with an estimated net worth of $1bn or more (individuals listed in Appendix B to the Report).
Pursuant to section 241(a)(2) of CAATSA, the US Treasury has also produced a classified annex on Russian parastatal entities (companies in which state ownership is at least 25% and that had 2016 revenues of approximately $2bn or more). The Report states that the classified annex may also include further individuals not included in Appendixes A and B (i.e. other senior foreign political figures and oligarchs in the Russian Federation), as well as people who hold a position below those included in the Report or have a net worth below $1bn.
Although the Report is not a sanctions list, Treasury Secretary Steven Mnuchin has informed the Senate Banking Committee that the Treasury would be using the Report to inform future targeted sanctions, and that “there will sanctions that come out of this”.
We previously reported that under section 231 of CAATSA, the US administration had until the 29 January 2018 to detail a list of people for sanctions that have knowingly engaged in a “significant transaction” with Russia’s defence or intelligence sectors. The State Department has stated that “when and if we have sanctions to announce, we will do so”.