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?

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.

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.

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.

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 Head of the Presidential Administration Anton Vaino First Deputy Head of the Presidential Administration Alexei Gromov First Deputy Head of the Presidential Administration Sergei Kiriyenko Deputy Head of the Presidential Administration Magomedsalam Magomedov Deputy Head of the Presidential Administration Vladimir Ostrovenko Presidential Press Secretary Dmitry Peskov Head of the Presidential Protocol Office Vladislav Kitayev Presidential Aide Andrei Belousov Presidential Aide Larisa Brycheva Presidential Aide Vladislav Surkov Presidential Aide Igor Levitin Presidential Aide Vladimir Kozhin Presidential Aide Yuri Ushakov Presidential Aide Andrei Fursenko Presidential Aide Nikolai Tsukanov Presidential Aide Konstantin Chuichenko Presidential Aide Yevgeny Shkolov Presidential Aide Igor Shchyogolev Presidential Adviser Alexander Bedritsky Presidential Adviser Sergei Glazyev Presidential Adviser Sergei Grigorov Presidential Adviser German Klimenko Presidential Adviser Anton Kobyakov Presidential Adviser Alexandra Levitskaya Presidential Adviser Vladimir Tolstoy Chairman of the Human Rights Council Mikhail Fedotov Presidential Adviser Veniamin Yakovlev Presidential Plenipotentiary Representative to the Federation Council Artur Muravyov Presidential Plenipotentiary Representative to the State Duma Garry Minkh Presidential Plenipotentiary Representative to the Constitutional Court Mikhail Krotov Presidential Commissioner for Children’s Rights Anna Kuznetsova Presidential Commissioner for the Protection of Entrepreneurs’ Rights Boris Titov Presidential Plenipotentiary Representative to the Volga Federal District Mikhail Babich Presidential Plenipotentiary Representative to the Northwestern Federal District Alexander Beglov Presidential Plenipotentiary Representative to the North Caucasus Federal District Oleg Belaventsev Presidential Plenipotentiary Representative to the Central Federal District Alexei Gordeyev Presidential Plenipotentiary Representative to the Siberian Federal District Sergei Menyailo Presidential Plenipotentiary Representative to the Far Eastern Federal District Yuri Trutnev Presidential Plenipotentiary Representative to the Southern Federal District Vladimir Ustinov Presidential Plenipotentiary Representative to the Ural Federal District Igor Kholmanskikh Head of the Presidential Administration Directorate for Foreign Policy Alexander Manzhosin Head of the Presidential Directorate for Interregional and Cultural Relations with Foreign Countries Vladimir Chernov 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 Prime Minister Dmitry Medvedev First Deputy Prime Minister Igor Shuvalov Chief of Government Staff Sergei Prikhodko Deputy Prime Minister Alexander Khloponin Deputy Prime Minister Vitaly Mutko Deputy Prime Minister Arkady Dvorkovich Deputy Prime Minister Olga Golodets Deputy Prime Minister Dmitry Kozak Deputy Prime Minister Dmitry Rogozin Minister for Open Government Mikhail Abyzov Minister of Agriculture Alexander Tkachev Head of the Ministry of Emergency Situations Vladimir Puchkov Minister of Communications Nikolai Nikiforov Minister of Construction, Housing, and Utilities Mikhail Men Minister of Culture Vladimir Medinsky Minister of Defense Sergei Shoigu Head of the Ministry of Economic Development Maxim Oreshkin Minister of Education Olga Vasilyeva Minister of Energy Alexander Novak Minister for the Development of the Far East Alexander Galushka Minister of Finance Anton Siluanov Minister of Foreign Affairs Sergei Lavrov Head of the Ministry of Health Veronika Skvortsova Head of the Ministry of Industry and Trade Denis Manturov Minister of Internal Affairs Vladimir Kolokoltsev Minister of Justice Alexander Konovalov Minister of Labor Maxim Topilin Head of the Ministry of Natural Resources Sergei Donskoy Minister for North Caucasus Affairs Lev Kuznetsov Minister of Sport Pavel Kolobkov Minister of Transport Maxim Sokolov Other senior political figures Speaker of the Federation Council Valentina Matviyenko Director of the SVR (Foreign Intelligence Service) Sergei Naryshkin Speaker of the State Duma Vyacheslav Volodin Presidential Special Representative for Environmental Protection, Ecology, and Transport Sergei Ivanov Secretary of the Russian Security Council Nikolai Patrushev Head of the Federal Customs Service Vladimir Bulavin Chief of the General Staff of the Armed Forces Valery Gerasimov Head of the GRU (military intelligence) Igor Korobov Deputy Secretary of the Russian Security Council Rashid Nurgaliyev Governor of St. Petersburg Georgy Poltavchenko Mayor of Moscow Sergei Sobyanin Prosecutor General Yuri Chaika Head of the Investigative Committee Alexander Bastrykin Head of the National Guard (Rosgvardiya) Viktor Zolotov Director of the Federal Protective Service Dmitry Kochnev Director of the FSB (Federal Security Service) Alexander Bortnikov Head of Rosarkhiv (the Federal Archives Agency) Andrei Artizov Director of Rosfinmonitoring (the federal financial monitoring service) Yuri Chikhanchin Head of the Main Directorate for Special Programs of the President Alexander Linets Presidential Property Manager Alexander Kolpakov Director of the State Courier Service Valery Tikhonov Chairman of the Management Board of Gazprom Alexei Miller Chief Executive Officer of Rosneft Igor Sechin President of Sberbank German Gref CEO of Russian Railways Oleg Belozerov President and Chairman of the Management Board of VTB Andrei Kostin CEO of Rostec Sergei Chemezov Former CEO of Rosseti Oleg Budargin Chairman of the Management Board of Inter RAO UES Boris Kovalchuk CEO of Rosatom Alexei Likhachev Chairman of the Management Board and President of Transneft Nikolai Tokarev Chairman of the Management Board of Gazprombank Andrei Akimov CEO of Tatneft Nail Maganov CEO of Aeroflot Vitaly Savelyev President of Bashneft Andrei Shishkin President of the United Aircraft Corporation Yuri Slyusar Chairman of the Management Board and CEO of RusHydro Nikolai Shulginov Chairman of Vnesheconombank Sergei Gorkov President of the diamond mining company Alrosa Sergei Ivanov Chief Executive Officer of Sakhalin Energy Roman Dashkov “List of Oligarchs” Alexander Abramov Roman Abramovich Araz Agalarov Farkhad Akhmedov Vagit Alekperov Igor Altushkin Alexei Ananyev Dmitry Ananyev Vasily Anisimov Roman Avdeyev Pyotr Aven Yelena Baturina Alexei Bogachev Vladimir Bogdanov Leonid Boguslavsky Andrei Bokarev Oleg Boyko Nikolai Buynov Oleg Deripaska Alexander Dzhaparidze Leonid Fedun Gleb Fetisov Mikhail Fridman Alexander Frolov Filaret Galchev Sergei Galitsky Valentin Gapontsev Sergei Gordeyev Andrei Guryev Yuri Gushchin Mikhail Gutseriev Sait-Salam Gutseriev Zarakh Iliev Dmitry Kamenshchik Vyacheslav Kantor Samvel Karapetyan Yevgeny Kaspersky Sergei Katsiev Suleiman Kerimov Igor Kesaev Danil Khachaturov German Khan Viktor Kharitonin Alexander Klyachin Pyotr Kondrashov Andrei Kosogov Yuri Kovalchuk Andrei Kozitsyn Alexei Kuzmichev Lev Kvetnoy Vladimir Lisin Anatoly Lomakin Ziyavudin Magomedov Igor Makarov Iskander Makhmudov Alexander Mamut Andrei Melnichenko Leonid Mikhelson Yuri Milner Boris Mints Andrei Molchanov Alexei Mordashov Vadim Moshkovich Alexander Nesis God Nisanov Alexander Ponomarenko Sergei Popov Vladimir Potanin Mikhail Prokhorov Dmitry Pumpyansky Megdet Rakhimkulov Andrei Rappoport Viktor Rashnikov Arkady Rotenberg Boris Rotenberg Dmitry Rybolovlev Airat Shaimiev Radik Shaimiev Kirill Shamalov Yuri Shefler Albert Shigabutdinov Mikail Shishkhanov Leonid Simanovsky Andrei Skoch Alexander Skorobogatko Rustem Sulteyev Alexander Svetakov Gennady Timchenko Oleg Tinkov Roman Trotsenko Alisher Usmanov Viktor Vekselberg Arkady Volozh Vadim Yakunin Vladimir Yevtushenkov Gavriil Yushvayev

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