Twelve minutes ahead of the deadline set by Congress back in August, the U.S. Treasury Department issued a highly anticipated report listing Russian oligarchs and senior political figures.  That sound you heard at 11:48 last night?  A host of wealthy Russians heaving sighs of relief.

The “Countering America’s Adversaries Through Sanctions Act,” (CAATSA) which was passed with overwhelming bipartisan support last summer, instituted new sanctions against Russia related to its interference with Ukraine and its alleged tampering with the 2016 presidential election.

But it also required the Treasury Department to issue, no later than yesterday, a report identifying Russian oligarchs with close ties to Vladimir Putin. The report was to identify “the most significant senior political figures and oligarchs in the Russian federation . . . as determined by their closeness to the Russian regime and their net worth.”  The report was required to detail the relationship between identified oligarchs and President Vladimir Putin or “other members of the Russian ruling elite,” “any indices of corruption with respect to those individuals, “their net worth and known sources of their (and their families’) income, and the non-Russian business affiliations of those individuals.”

In addition to reporting on individuals, the report was to identify “Russian parastatal entities,” their leadership structures and beneficial ownership, and the scope of their non-Russian business affiliations.
Continue Reading

The Philippines has been identified by the U.S. as a “major money-laundering country” in the 2017 International Narcotics Control Strategy Report (“Report”), published this month. The country now joins 87 others as one “whose financial institutions engage in currency transactions involving significant amounts of proceeds from international narcotics trafficking.” See 22 U.S.C. § 2291(e)(7).

By