In the morning, everyone was eagerly examining the new U.S. “sanctions” list of 210 people. People joked that it was basically the Forbes list plus the Kremlin phone directory. They were surprised by who was included and who was left out. They also mocked the failed predictions about “20–25 people” or 1,000 officials and their family members.

So what does this list actually mean?

1. This is not a sanctions list, and no formal sanctions have yet been imposed on the people named in it. It is the public part of a report prepared in accordance with the requirements of last year’s law, the Countering America’s Adversaries Through Sanctions Act. In this public, non-classified section, the people listed are essentially those on whom the U.S. Treasury is collecting and processing information. 2. The classified part of the report, however, may include other individuals, as well as detailed information on those named in the public section. In the classified section, importantly, the report assesses closeness to Putin, involvement in corruption, the sources of income of those listed and their family members, and their ties abroad. So it is quite possible that there are no new names in the classified section at all—just substantive material on some of the people from the public list. One can say with confidence that the United States is collecting and processing—or has already collected—information on those named in the public section in order to make future decisions on personal sanctions. 3. At the same time, as we have said before, simply being included in this report deals a serious blow to a person’s reputation in international business. Bank compliance departments will spend a long and painful time checking the sources of income and documents of the people on the list. Business relationships abroad will require a “risk premium,” and some especially cautious partners will cut off all ties altogether. Fatal? No. Additional problems? Yes. 4. It is also worth adding that, as we can see from the inclusion of Artyom Chaika in the toughest sanctions list, analytical work on Russian corrupt officials is underway and their histories are being studied closely. The wording under which the younger Chaika was sanctioned suggests that U.S. Treasury staff know exactly what they are dealing with. Hopefully, they will study the biographies of the 210 people on today’s list just as carefully.

P.S. What is truly disappointing about this list is the absence of representatives of Russia’s judiciary. If independent courts actually functioned in Russia, the current authorities would not have been able to do much of what they have done.

List of Senior Officials Presidential Administration 1. Head of the Presidential Administration Anton Vaino 2. First Deputy Head of the Presidential Administration Alexei Gromov 3. First Deputy Head of the Presidential Administration Sergei Kiriyenko 4. Deputy Head of the Presidential Administration Magomedsalam Magomedov 5. Deputy Head of the Presidential Administration Vladimir Ostrovenko 6. Presidential Press Secretary Dmitry Peskov 7. Head of the Presidential Protocol Office Vladislav Kitayev 8. Presidential Aide Andrei Belousov 9. Presidential Aide Larisa Brycheva 10. Presidential Aide Vladislav Surkov 11. Presidential Aide Igor Levitin 12. Presidential Aide Vladimir Kozhin 13. Presidential Aide Yuri Ushakov 14. Presidential Aide Andrei Fursenko 15. Presidential Aide Nikolai Tsukanov 16. Presidential Aide Konstantin Chuichenko 17. Presidential Aide Yevgeny Shkolov 18. Presidential Aide Igor Shchyogolev 19. Presidential Adviser Alexander Bedritsky 20. Presidential Adviser Sergei Glazyev 21. Presidential Adviser Sergei Grigorov 22. Presidential Adviser German Klimenko 23. Presidential Adviser Anton Kobyakov 24. Presidential Adviser Alexandra Levitskaya 25. Presidential Adviser Vladimir Tolstoy 26. Chairman of the Human Rights Council Mikhail Fedotov 27. Presidential Adviser Veniamin Yakovlev 28. Presidential Plenipotentiary Representative to the Federation Council Artur Muravyov 29. Presidential Plenipotentiary Representative to the State Duma Garry Minkh 30. Presidential Plenipotentiary Representative to the Constitutional Court Mikhail Krotov 31. Presidential Commissioner for Children’s Rights Anna Kuznetsova 32. Presidential Commissioner for the Protection of Entrepreneurs’ Rights Boris Titov 33. Presidential Plenipotentiary Representative to the Volga Federal District Mikhail Babich 34. Presidential Plenipotentiary Representative to the Northwestern Federal District Alexander Beglov 35. Presidential Plenipotentiary Representative to the North Caucasus Federal District Oleg Belaventsev 36. Presidential Plenipotentiary Representative to the Central Federal District Alexei Gordeyev 37. Presidential Plenipotentiary Representative to the Siberian Federal District Sergei Menyailo 38. Presidential Plenipotentiary Representative to the Far Eastern Federal District Yuri Trutnev 39. Presidential Plenipotentiary Representative to the Southern Federal District Vladimir Ustinov 40. Presidential Plenipotentiary Representative to the Ural Federal District Igor Kholmanskikh 41. Head of the Presidential Administration Directorate for Foreign Policy Alexander Manzhosin 42. Head of the Presidential Directorate for Interregional and Cultural Relations with Foreign Countries Vladimir Chernov 43. Head of the Presidential Directorate for Socioeconomic Cooperation with the CIS States, the Republic of Abkhazia, and the Republic of South Ossetia Oleg Govorun Government 44. Prime Minister Dmitry Medvedev 45. First Deputy Prime Minister Igor Shuvalov 46. Chief of Government Staff Sergei Prikhodko 47. Deputy Prime Minister Alexander Khloponin 48. Deputy Prime Minister Vitaly Mutko 49. Deputy Prime Minister Arkady Dvorkovich 50. Deputy Prime Minister Olga Golodets 51. Deputy Prime Minister Dmitry Kozak 52. Deputy Prime Minister Dmitry Rogozin 53. Minister for Open Government Mikhail Abyzov 54. Minister of Agriculture Alexander Tkachev 55. Head of the Ministry of Emergency Situations Vladimir Puchkov 56. Minister of Communications Nikolai Nikiforov 57. Minister of Construction, Housing, and Utilities Mikhail Men 58. Minister of Culture Vladimir Medinsky 59. Minister of Defense Sergei Shoigu 60. Head of the Ministry of Economic Development Maxim Oreshkin 61. Minister of Education Olga Vasilyeva 62. Minister of Energy Alexander Novak 63. Minister for the Development of the Far East Alexander Galushka 64. Minister of Finance Anton Siluanov 65. Minister of Foreign Affairs Sergei Lavrov 66. Head of the Ministry of Health Veronika Skvortsova 67. Head of the Ministry of Industry and Trade Denis Manturov 68. Minister of Internal Affairs Vladimir Kolokoltsev 69. Minister of Justice Alexander Konovalov 70. Minister of Labor Maxim Topilin 71. Head of the Ministry of Natural Resources Sergei Donskoy 72. Minister for North Caucasus Affairs Lev Kuznetsov 73. Minister of Sport Pavel Kolobkov 74. Minister of Transport Maxim Sokolov Other senior political figures 75. Speaker of the Federation Council Valentina Matviyenko 76. Director of the SVR (Foreign Intelligence Service) Sergei Naryshkin 77. Speaker of the State Duma Vyacheslav Volodin 78. Presidential Special Representative for Environmental Protection, Ecology, and Transport Sergei Ivanov 79. Secretary of the Russian Security Council Nikolai Patrushev 80. Head of the Federal Customs Service Vladimir Bulavin 81. Chief of the General Staff of the Armed Forces Valery Gerasimov 82. Head of the GRU (military intelligence) Igor Korobov 83. Deputy Secretary of the Russian Security Council Rashid Nurgaliyev 84. Governor of St. Petersburg Georgy Poltavchenko 85. Mayor of Moscow Sergei Sobyanin 86. Prosecutor General Yuri Chaika 87. Head of the Investigative Committee Alexander Bastrykin 88. Head of the National Guard (Rosgvardiya) Viktor Zolotov 89. Director of the Federal Protective Service Dmitry Kochnev 90. Director of the FSB (Federal Security Service) Alexander Bortnikov 91. Head of Rosarkhiv (the Federal Archives Agency) Andrei Artizov 92. Director of Rosfinmonitoring (the federal financial monitoring service) Yuri Chikhanchin 93. Head of the Main Directorate for Special Programs of the President Alexander Linets 94. Presidential Property Manager Alexander Kolpakov 95. Director of the State Courier Service Valery Tikhonov 96. Chairman of the Management Board of Gazprom Alexei Miller 97. Chief Executive Officer of Rosneft Igor Sechin 98. President of Sberbank German Gref 99. CEO of Russian Railways Oleg Belozerov 100. President and Chairman of the Management Board of VTB Andrei Kostin 101. CEO of Rostec Sergei Chemezov 102. Former CEO of Rosseti Oleg Budargin 103. Chairman of the Management Board of Inter RAO UES Boris Kovalchuk 104. CEO of Rosatom Alexei Likhachev 105. Chairman of the Management Board and President of Transneft Nikolai Tokarev 106. Chairman of the Management Board of Gazprombank Andrei Akimov 107. CEO of Tatneft Nail Maganov 108. CEO of Aeroflot Vitaly Savelyev 109. President of Bashneft Andrei Shishkin 110. President of the United Aircraft Corporation Yuri Slyusar 111. Chairman of the Management Board and CEO of RusHydro Nikolai Shulginov 112. Chairman of Vnesheconombank Sergei Gorkov 113. President of the diamond mining company Alrosa Sergei Ivanov 114. Chief Executive Officer of Sakhalin Energy Roman Dashkov List of Oligarchs 1. Alexander Abramov 2. Roman Abramovich 3. Araz Agalarov 4. Farkhad Akhmedov 5. Vagit Alekperov 6. Igor Altushkin 7. Alexei Ananyev 8. Dmitry Ananyev 9. Vasily Anisimov 10. Roman Avdeyev 11. Pyotr Aven 12. Yelena Baturina 13. Alexei Bogachev 14. Vladimir Bogdanov 15. Leonid Boguslavsky 16. Andrei Bokarev 17. Oleg Boyko 18. Nikolai Buynov 19. Oleg Deripaska 20. Alexander Dzhaparidze 21. Leonid Fedun 22. Gleb Fetisov 23. Mikhail Fridman 24. Alexander Frolov 25. Filaret Galchev 26. Sergei Galitsky 27. Valentin Gapontsev 28. Sergei Gordeyev 29. Andrei Guryev 30. Yuri Gushchin 31. Mikhail Gutseriev 32. Sait-Salam Gutseriev 33. Zarakh Iliev 34. Dmitry Kamenshchik 35. Vyacheslav Kantor 36. Samvel Karapetyan 37. Yevgeny Kaspersky 38. Sergei Katsiev 39. Suleiman Kerimov 40. Igor Kesaev 41. Danil Khachaturov 42. German Khan 43. Viktor Kharitonin 44. Alexander Klyachin 45. Pyotr Kondrashov 46. Andrei Kosogov 47. Yuri Kovalchuk 48. Andrei Kozitsyn 49. Alexei Kuzmichev 50. Lev Kvetnoy 51. Vladimir Lisin 52. Anatoly Lomakin 53. Ziyavudin Magomedov 54. Igor Makarov 55. Iskander Makhmudov 56. Alexander Mamut 57. Andrei Melnichenko 58. Leonid Mikhelson 59. Yuri Milner 60. Boris Mints 61. Andrei Molchanov 62. Alexei Mordashov 63. Vadim Moshkovich 64. Alexander Nesis 65. God Nisanov 66. Alexander Ponomarenko 67. Sergei Popov 68. Vladimir Potanin 69. Mikhail Prokhorov 70. Dmitry Pumpyansky 71. Megdet Rakhimkulov 72. Andrei Rappoport 73. Viktor Rashnikov 74. Arkady Rotenberg 75. Boris Rotenberg 76. Dmitry Rybolovlev 77. Airat Shaimiev 78. Radik Shaimiev 79. Kirill Shamalov 80. Yuri Shefler 81. Albert Shigabutdinov 82. Mikail Shishkhanov 83. Leonid Simanovsky 84. Andrei Skoch 85. Alexander Skorobogatko 86. Rustem Sulteyev 87. Alexander Svetakov 88. Gennady Timchenko 89. Oleg Tinkov 90. Roman Trotsenko 91. Alisher Usmanov 92. Viktor Vekselberg 93. Arkady Volozh 94. Vadim Yakunin 95. Vladimir Yevtushenkov 96. Gavriil Yushvayev

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