What Lies Beneath – Mapping Oligarch Risk May 2018


Who is close to Putin and the Kremlin? The US Treasury Department has produced a list of oligarchs, as required by CAATSA Section 241, which may be subject to future sanctions. Initially the list was seen as relatively innocuous, but since several oligarchs and some important Russian companies were added to the SDN list on April 6th, the Section 241 list is now being more closely scrutinized by investors, lenders and counterparties in an effort to understand who may be at risk should there be any further similar sanctions.