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Treasury Department Releases Russian Oligarch List and Promises Future Sanctions, But No Russia Sanctions Issued Yet as Key Deadlines Pass


By: Michael T. Gershberg, Justin A. Schenck

On January 29, 2018, the U.S. Department of the Treasury delivered five sanctions-related reports to Congress as required under the Countering America's Adversaries Through Sanctions Act (CAATSA), including the long-awaited Section 241 report on Senior Political Figures and Oligarchs in the Russian Federation.  Although no sanctions were immediately imposed on members of the so-called “Oligarch List,” the potential for future sanctions is real.  Also, the U.S. State Department announced that no secondary sanctions would be imposed under Section 231 of CAATSA on foreign persons engaging in significant transactions with the Russian defense and intelligence sectors, noting that the threat of sanctions is already serving as a deterrent to such transactions.  While no new sanctions were announced in conjunction with these steps, Treasury Secretary Mnuchin stated that future sanctions against Russia are in the pipeline and will be based on the Section 241 list and other reports delivered by Treasury.

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