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7th February 2018 – Last week, the US Treasury released its much-anticipated ‘Kremlin List’. The List contains the names of over two hundred Russian political or business figures, ranging from billionaires who made their fortunes in the tumultuous 1990s to members of President Putin’s current administration. For advocates of tougher sanctions on Russia, the List was a disappointment. No new sanctions were introduced, and the List lacked nuance and analysis.

The list of businesspeople, for example, appears to have been taken directly from Forbes’ ranking of Russia’s wealthiest individuals, some of whom have no tangible link to the Putin government. The US Treasury has batted the criticism away, however, indicating that the List contains a classified section running into hundreds of pages, which may form the basis of a new round of sanctions.

This briefing note examines the reaction to the publication of the Kremlin List in the context of international sanctions on Russia and considers the potential flaws in its methodology. If you have any questions regarding the Kremlin List and how it may affect your dealings with clients from Russia, please contact S-RM’s Russia & CIS team for an in-depth discussion.