Monthly Archives: January 2018

January 30, 2018

Upcoming Russian Corruption Designations Likely to be Challenged

by  Jeremy Paner

Late last month, the U.S. Government sanctioned a number of alleged human rights abusers and corrupt actors located throughout the world.  The White House and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed these sanctions more than a year after Congress delegated the underlying designation authority pursuant to the Global Magnitsky Human Rights Accountability Act.[1] While the annex to the Executive Order implementing these sanctions lists two Russian individuals, the sanctions do not focus on the alleged corruption and human rights abuses of any particular country or region.  OFAC is likely to concentrate future corruption-related sanctions on Russia following the submission of a Congressionally mandated report due by the end of this month.

Section 241 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) requires the U.S. Department of the Treasury to submit a report to Congress by January 29, providing certain information on allegedly corrupt Russian oligarchs and parastatal entities.  Most importantly, this report will opine on the likely effects of various sanctions, including debt and equity restrictions, blocking parastatal entities, and imposing secondary sanctions.[2]  It appears that Congress will use the conclusions of this report to delegate additional corruption-related sanctions authorities in the near future.  Continue reading