As required by Section 241 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) (see our Trump and Trade Update dated 10/30/17), the Treasury Department has submitted to Congress a detailed and classified report identifying senior Russian political figures, Russian oligarchs and Russian parastatal entities (companies in which Russian state ownership is at least 25 percent and that had revenues of $2 billion or more). While the list of parastatal entities remains classified, Treasury has released an unclassified report on the list of senior Russian political figures and oligarchs. This unclassified list includes virtually every senior member of Vladimir Putin’s inner circle and nearly 100 Russian billionaires; the classified list reportedly details the relationships these individuals have with President Putin and any information on their involvement in corrupt activities. This report is not a sanctions list; the inclusion of individuals or entities in any portion of the report does not impose sanctions on those individuals or entities, nor does it create any other restrictions, prohibitions or limitations on dealings with such persons by either U.S. or foreign persons. However, many of those listed are already sanctioned for their alleged involvement in the illegal annexation of the Crimea region of Ukraine, malicious cyber incursions into the United States, and interference in the 2016 U.S. presidential election. The Treasury Department stated that it will rely on all available sources of information, including the classified version of this report, when making determinations about additional sanctions in the future. Putin responded to the release of the list by calling it “nonsense” that would “reduce our bilateral relationship to zero.”

In a related move, the State Department announced that the president would postpone any sanctions on persons or entities engaging in any significant transactions involving the Russian defense or intelligence sectors pursuant to Section 231 of CAATSA. Under CAATSA, President Trump is required to impose at least five sanctions on persons or entities that may be engaging in such transactions; however, he is allowed to postpone these sanctions. A spokesperson for the State Department indicated that no actions would be taken at this time as the law was already “serving as a deterrent.”