US Sectoral Sanctions

CAATSA / Guidances / Lists (cont'd) - CAATSA section 241 Report and Lists: US Treasury Dep't in January 2018 issued its required Report to Congress (per CAATSA sec. 241) re Russia's senior political figures, oligarchs and parastatal entities Comprising an unclassified main report with list-appendices, and a classified annex This Report was not a sanctions list (as stated in the Report itself, and in OFAC's accompanying FAQ 552, and in CAATSA sec. 241 itself) The unclassified part listed 114 senior political figures - in the Presidential Administration, Cabinet of Ministers, and "other senior political leaders" (including the CEOs of many of Russia's largest majority state-owned companies such as Messrs. Miller, Sechin, Gref, Kostin and Chemezov - some of whom were already or have since become SDNs) and 96 "oligarchs" - Russian individuals having a net worth estimated at $1 billion (apparently just taken from the Forbes list, set out in alphabetical order ... a few having since become SDNS- see slide 33 above) The classified annex (submitted only to Congress) apparently featured < a list of Russia's "parastatal entities" (companies having ≥25% state ownership and 2016 revenues of >$2 billion - see such an unofficial list, in Russian, created / published by Kommersant newspaper on 30 Jan. 2018), an assessment of their role in Russia's economy, etc. the oligarchs' (apparently including some not included on the unclassified list of 96) "closeness to the Russian regime" and sources of income, location of assets, etc. an overview of key US economic sectors' exposure to Russian persons and entities an analysis of possible impact of additional sanctions on these persons / entities Morgan Lewis 56 56

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