Wednesday, May 27, 2020


In its Report to Congress, pursuant to the Countering America's Adversaries Through Sanction Act, Treasury included its list of Russian Oligarchs. These are individuals, all of whom qualify because they are known to possess more One Billion ($1,000,000,000) Dollars, all of which was diverted government property, for which they paid little or nothing, at the time of the dissolution of the former Soviet Union.

Needless to say, these are not individuals that you ever want to meet in a dark alley at midnight, for their bodyguards would probably shoot first, and ask questions later. Should you encounter any documents referring to any one of these Oligarchs, for any reason, are grounds to immediately conduct enhanced due diligence upon your client and all counterparties, the transactions involved, and whether there have been any prior references to that individual in transactions, records or correspondence, You should also seek the advice of the bank's outside attorneys, or other competent legal counsel.

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