NEW US LIST OF RUSSIAN PERSONS INCLUDING OLIGARCHS WHO MIGHT BE MADE SUBJECT TO SANCTIONS

NEW OFAC FAQ ON LIST OF RUSSIAN PERSONS/ENTITIES THAT MIGHT BE MADE SUBJECT TO SANCTIONS

On 30th January the US Treasury announced that OFAC had published a new FAQ regarding the Treasury report on oligarchs and parastatal entities of the Russian Federation as required by section 241 of the Counter America’s Adversaries Through Sanctions Act (CAATSA).  Issued on 29th January, this list was of persons and entities that could be liable to sanctions under the Act.   The new question was –

Has the Treasury Department now sanctioned the individuals and entities included in its January 29, 2018 report on senior political figures, oligarchs, and parastatal entities of the Russian Federation?

The response is –

No.  Pursuant to section 241 of Countering America’s Adversaries Through Sanctions Act of 2017 (Pub. L. 115-44), the Treasury Department, in consultation with Secretary of State and the Director of National Intelligence, delivered a report on January 29, 2018 to the specified congressional committees regarding significant senior political figures and oligarchs in the Russian Federation and Russian parastatal entities.

This report is not a “sanctions list.”  While some persons mentioned in the report may have been sanctioned pursuant to other authorities, the inclusion of individuals or entities in this report, its appendices, or its classified annex does not and in no way should be interpreted to impose sanctions on those individuals or entities.  Inclusion in this report also does not constitute a determination by any agency that any of those individuals or entities meet the criteria for designation under any sanctions program.  Moreover, the inclusion of individuals or entities in this report, its appendices, or its classified annex does not, in and of itself, imply, give rise to, or create any restrictions, prohibitions, or limitations on dealings with such persons by either US or foreign persons.  Neither does inclusion in the unclassified report indicate that the US Government has information about the individual’s involvement in malign activities.  [1-30-2018]

https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_other.aspx#552

THE LIST ITSELF –

The US Treasury news release from 29th January about the listing (included as part of 5 reports due under the Act) is at –

https://home.treasury.gov/news/press-releases/sm0271

The lists include names 114 senior Russian political figures and 96 “oligarchs” who US authorities say have gained wealth or power through association with Putin, including  aluminum magnate Oleg Deripaska, Chelsea football club owner Roman Abramovich and the media and tech magnate Alisher Usmanov.

See also –

http://www.klgates.com/further-implementation-of-sanctions-legislation-01-29-2018/

https://www.cnbc.com/2018/01/30/read-the-full-oligarch-list-of-top-russian-business-leaders.html

The list is at –

https://www.scribd.com/document/370313106/2018-01-29-Treasury-Caatsa-241-Final#from_embed

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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