Treasury Sanctions Global Russian Military Supply Chain, Kremlin-linked Networks, and Elites with Western Fortunes

Date issued: Nov. 14 2022

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TURBOFAC Commentary (124 words)

Notes:

1) As of 11-20-22, this is the only designation based on the "management consulting" sector-related determination (Determination Pursuant to Executive Order 14024 of April 15, 2021 (Effective May 8, 2022)).

The designation notice includes the designation of "Swiss national Alexander-Walter Studhalter," who was reported as having "allegedly laundered significant amounts of money on [a Russian SDN's] behalf". Given the allegations of illegality, the designation notice does not qualify as a proper "quasi-secondary sanctions" action (as described in Introductory Note Common to all Derivative Designation Notices Included in the Research System), but the designation notice is notable for its interpretation of "management consulting sector[] of the Russian Federation economy" that includes Western entities providing such services to Russian individuals.