U.S. Treasury Severs More Networks Providing Support for Putin and Russia’s Elites

Date issued: Jun. 02 2022

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TURBOFAC Commentary (112 words)

Notes:

1) See Introductory Note Common to all Derivative Designation Notices Included in the Research System, and query whether the Imperial Yachts designation qualifies as a "quasi-secondary sanctions" action. We have included this announcement for the avoidance of doubt, since it is arguably the first secondary sanctions-like action taken against Russia since the start of the Ukraine invasion, but in this case the entity at issue, while based in Monaco, is arguably alleged to have engaged in illicit conduct. It is not clear whether the context of "hide, move, and maintain their wealth and luxury assets" is transactions that are otherwise legal in the jurisdictions having authority over the transactions.