In case we weren’t clear…

Yesterday, OFAC added the following Frequently Asked Question about the recently released CAATSA Section 241 List (aka “The Kremlin Report”):

552. Has the Treasury Department now sanctioned the individuals and entities included in its January 29, 2018 report on senior political figures, oligarchs, and parastatal entities of the Russian Federation?  
No.  Pursuant to section 241 of Countering America’s Adversaries Through Sanctions Act of 2017 (Pub. L. 115-44), the Treasury Department, in consultation with Secretary of State and the Director of National Intelligence, delivered a report on January 29, 2018 to the specified congressional committees regarding significant senior political figures and oligarchs in the Russian Federation and Russian parastatal entities.  
This report is not a “sanctions list.”  While some persons mentioned in the report may have been sanctioned pursuant to other authorities, the inclusion of individuals or entities in this report, its appendices, or its classified annex does not and in no way should be interpreted to impose sanctions on those individuals or entities.  Inclusion in this report also does not constitute a determination by any agency that any of those individuals or entities meet the criteria for designation under any sanctions program.  Moreover, the inclusion of individuals or entities in this report, its appendices, or its classified annex does not, in and of itself, imply, give rise to, or create any restrictions, prohibitions, or limitations on dealings with such persons by either U.S. or foreign persons.  Neither does inclusion in the unclassified report indicate that the U.S. Government has information about the individual’s involvement in malign activities.  [1-30-2018]

Nothing to see here… move along. The only question now is: will Congress now pass a follow-on bill to force the Administration to impose sanctions?


OFAC Notice

New CAATSA Section 241 FAQ

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