On 28 May, Kenneth Rijock in his blog made available the list produced for the US Congress by the Treasury and including individuals, all of whom qualify because they are known to possess more $1 billion – all of which was diverted government property, for which they paid little or nothing, at the time of the dissolution of the former Soviet Union.  He suggests that involvement of any of them would trigger enhanced due diligence upon your client and all counterparties, the transactions involved etc.



If you would like to say thanks by making a small contribution, in case I need to upgrade or replace my computers and other paraphernalia, I have a page at

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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