The Treasury Department today released the much-anticipated list of “the most significant senior foreign political figures and oligarchs in the Russian Federation” required by Section 241 of CAATSA. As we have long advised, the list has no immediate legal impact, and it appears that at least in the short to medium term it is unlikely to affect U.S. sanctions policy. The list is a mechanical compilation of 210 names using objective criteria and, at least in its unclassified version, provides little basis to single individuals out for sanctions.

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