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The Art Industry and U.S. Policies that Undermine Sanctions/Section 2A

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​ II. BACKGROUND

A. U.S. Sanctions Enforcement

Sanctions are a critical tool for combatting national security threats and advancing foreign policy objectives.[1] Sanctions as a U.S. foreign policy tool have grown in recent years, with presidents using sanctions to target terrorist organizations, punish foreign governments, and encourage adversaries to enter negotiations with the United States without resorting to military action.[2] In fact, during his first year in office, President Trump designated approximately 1,000 individuals and entities.[3] This is triple the number listed by President Obama during his first year, and 30 percent more than his last year in office.[4]

1. The U.S. Treasury Department

In 1789, Congress established the Treasury Department ("Treasury" or the "Department") to promote economic prosperity and ensure financial security.[5] Treasury's mission is to "maintain a strong economy and create economic and job opportunities by promoting the conditions that enable economic growth and stability at home and abroad, strengthen national security by combatting threats and protecting the integrity of the financial system, and manage the U.S. Government's finances and resources effectively."[6] This multi-faceted mandate reflects its central role in the U.S. economic and financial system.[7]

A key part of the Department's mission involves the implementation of economic sanctions against foreign actors and entities.[8] Established in 2004, the Department's Office of Terrorism and Financial Intelligence ("TFI") is responsible ​for enforcing economic sanctions as well as developing policy, strategies, and guidance to combat terrorist funding.[9]

The Office of Foreign Assets Control ("OFAC"), a division of TFI, reports directly to the Undersecretary for Terrorism and Financial Crimes.[10] OFAC's sanction authority stems from "[p]residential national emergency powers, as well as authority granted by specific legislation, to impose controls on transactions and freeze assets under U.S. jurisdiction."[11] Specific sanctions authorities include the Trading with the Enemy Act ("TWEA"), the International Emergency Economic Powers Act ("IEEPA"), and the Global Magnitsky Human Rights Accountability Act ("Magnitsky Act") as described below. OFAC is the office specifically tasked with the administration and enforcement of economic and trade sanctions developed by the President.[12]

The sanction authority tied to presidential emergency power dates back to the TWEA, which prohibits transactions with enemy persons and powers.[13] During the Cold War, TWEA was used "to block international financial transactions, seize U.S.-based assets held by foreign nationals, restrict exports, modify regulations to deter the hoarding of gold, limit foreign direct investment in U.S. companies, and impose tariffs on all imports into the United States."[14]

Since its enactment in 1977, IEEPA has also served as an important sanction authority that the president may exercise "to deal with an unusual and extraordinary threat with respect to . . . a national emergency" that "has its source in whole or substantial part outside the United States."[15] IEEPA has been amended several times since its enactment, but the change most relevant to the art market is the "Berman Amendment" passed in 1988.[16] This amendment exempted ​information and informational materials from presidential sanction authority under IEEPA and TWEA.[17] The Berman amendment specifically exempted the authority to regulate or prohibit "publications, films, posters, phonograph records, photographs, microfilms, microfiche, tapes, compact disks, CD ROMs, artworks, and new wire feeds."[18]

Additional sanctions authority available to the President is found in the Magnitsky Act.[19] Passed in 2016, the law authorizes the President to impose sanctions on any foreign person "who is responsible for extrajudicial killings, torture, or other gross violations of internationally recognized human rights" committed against individuals seeking to expose corruption or promote human rights.[20] President Trump has used this authority to designate individuals for offenses including wrongful detention, the denial of medical treatment for detainees, and the expropriation of businesses for personal gain.[21] OFAC implements its sanction authorities in ways "expected to generate the most impact in achieving [U.S.] national security and foreign policy goals."[22] In a 2017 hearing before the House Subcommittee on Monetary Policy, then-OFAC Director John Smith explained that "[w]hen deployed strategically and with precision, sanctions are a highly effective way of pressuring regimes and malign actors to change their behavior."[23] Director Smith further asserted:

[B]y freezing the assets of illicit actors, cutting them off from the U.S. financial system, and restricting their ability to interface with the international financial system, the choice to them becomes clear: either modify your behavior or accept the isolation and negative economic effects of remaining on our financial blacklist.[24]

In addition to sanctions, OFAC also designates individuals or entities as Specially Designated Nationals ("SDN").[25] The SDN list contains the names of "individuals and companies owned or controlled by, or acting on behalf of, targeted ​countries."[26] The list is not limited to state actors and contains non-country specific individuals, groups, and entities.[27] Currently, the list contains approximately 6,400 companies and individuals.[28]

Persons can be added to the SDN list in several ways. In some cases, the President issues an executive order directing the Secretary of the Treasury, in consultation with the Secretary of State, to identify individuals or entities that should be added to the list.[29] In other cases, the President directly identifies individuals or entities to designate as SDNS.[30] Once on the list, U.S. persons and businesses are prohibited from obtaining goods, services, or technology from SDNs, or otherwise transacting with them.[31] This prohibition extends to business conducted through third-party intermediaries.[32] Indeed, "[i]nclusion on the SDN List generally prohibits U.S. banks from maintaining accounts for those listed and U.S persons could face civil or criminal penalties for engaging in business dealing with them."[33]

Under Treasury Department guidance, a sanctioned individual may own a minority interest in a company and still access the U.S. financial system. OFAC's "50 percent rule," states that "any entity owned in the aggregate, directly or indirectly, 50 percent or more by one or more blocked persons is itself considered to be a blocked person."[34] This is significant because an entity meeting this standard incurs SDN restrictions even if the entity itself is not named on the SDN list.[35]

​2. Sanctions Following the Russian Federation's Invasion of Crimea

In 2014, President Obama issued a series of Executive Orders ("EO") that authorized Treasury to sanction individuals, assets, and companies in the Russian Federation ("Russia") following Russia's annexation of Crimea. On March 6, 2014, President Obama issued EO 13660 instructing Treasury to sanction any individual who "[undermined] democratic processes and institutions in Ukraine."[36] On March 16, 2014, President Obama authorized additional sanctions on "persons contributing to the situation in Ukraine" through EO 13661.[37] Under the authority of EO 13661, on March 20, 2014, Treasury designated 16 Russian government officials and four members of President Putin's inner circle, which included Arkady and Boris Rotenberg.[38][39] The European Union imposed similar restrictions in response to what it perceived as Russia's "deliberate destabilization of Ukraine."[40]

a. The Russian Invasion of Crimea

In early 2014, Russia invaded Crimea following a period of political turmoil in Ukraine.[41] This turmoil stemmed from Ukrainian President Viktor Yanukovych's November 2013 refusal to sign a "political association and free trade agreement with the European Union."[42] By February 22, 2014, the Ukrainian parliament voted unanimously to remove President Yanukovych.[43]

After his removal, Yanukovych fled to Russia.[44] Shortly thereafter, Moscow deployed forces to Crimea and declared the region as part of the Russian Federation.[45] This invasion was significant not only because of Crimea's ​strategically important geographic location, but also because it "violated the terms of a diplomatic agreement to respect Ukraine's borders, and placed Russia on a war footing with one of the few states in the post-Soviet world that has managed to hold free elections."[46] The Crimean parliament then voted to secede from Ukraine and join Russia, scheduling a referendum for ten days later.[47] When the referendum was held, 97 percent voted in favor of secession.[48] Two days later, Russian President Vladimir Putin signed a treaty of accession with the new leaders of Crimea.[49] Putin delivered an address in conjunction with the signing, asserting that Crimea was a part of Russia and confirming his disregard for an international border that was recognized for 23 years.[50] The United States, European Union, and Ukraine refused to recognize the annexation.[51] While maintaining that the annexation was illegal, the Ukrainian government withdrew military personnel and their families from Crimea.[52]

Since that time, Russia "has significantly increased its military presence in Crimea and suppressed local dissent."[53] Ukrainian officials now estimate 30,000 Russian troops are stationed in the region.[54] During the Russian occupation, the Office of the United Nations High Commissioner for Human Rights "documented 'multiple and grave' human rights violations in Crimea and said that minority Crimean Tatars, who are generally opposed to Russia's occupation, have been 'particularly targeted."[55]

​b. U.S. and E.U. Sanctions Following the Invasion of Crimea

In response to Russia's invasion of Crimea, both the United States and the European Union imposed sanctions against several key Russian individuals.[56] Since these Crimea-related sanctions, the United States has imposed additional sanctions on Russia for a range of offenses, including human rights abuses, election interference, cyberattacks, weapons proliferation, trade with North Korea, support for the Syrian government, and use of a chemical weapon.[57] As of July 2020, the list of individuals and entities sanctioned by the U.S. government related to Russia's annexation of Crimea stood at 701.[58]

On March 6, 2014, the United States imposed sanctions on Russia, when President Obama issued an executive order under IEEPA and announced coordinated sanctions with the United Kingdom in response to Russia's "violation of Ukraine's sovereignty and territorial integrity."[59] That EO 13660 did not specifically reference Russia by name, but it did target those whose "actions or policies . . . undermine democratic processes or institutions in Ukraine."[60] President Obama further noted that the planned referendum would violate the Ukrainian constitution, as well as international law, and noted that the Ukrainian government must be included in any discussion of Crimea's future.[61]

Following Crimea's referendum, the White House issued a statement saying, "the international community will not recognize the results of a poll administered under threats of violence and intimidation from a Russian military intervention that violates international law."[62] President Obama then signed EO 13661 on March 16, 2014, finding that Russia's deployment of military forces to Crimea undermined the "democratic processes and institutions in Ukraine; threaten its peace, security, stability, sovereignty, and territorial integrity; and contribute to the ​misappropriation of its assets, and thereby constitute an unusual and extraordinary threat to the national security and foreign policy of the United States."[63]

EO 13661 authorized sanctions against several specifically listed Russian government officials and instructed OFAC to identify additional individuals who "have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of a senior official of the Government of the Russian Federation."[64] Pursuant to the order, on March 20, 2014, OFAC designated 16 Russian government officials and 4 members of President Putin's inner circle, including Arkady and Boris Rotenberg.[65] President Obama later issued additional executive orders on March 20, 2014 and December 19, 2014, expanding the scope of the sanctions.[66]

In addition to executive branch actions, Congress passed two laws sanctioning Russian individuals and entities in 2014: (1) Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act and (2) Ukraine Freedom Support Act.[67] These laws permitted sanctions against any person "the President determines has perpetrated, or is responsible for ordering, controlling, or otherwise directing, significant acts of violence or gross human rights abuses in Ukraine."[68] They also included "potentially wide-reaching secondary sanctions against foreign individuals and entities that facilitate significant transactions for Russia sanctions designees, help them to evade sanctions, or make significant investments in certain oil projects in Russia."[69]

Like the United States, the European Union also issued economic sanctions against Russia for its invasion of Ukraine.[70] These restrictions included bans on "goods originating in Crimea . . . unless they have Ukrainian certificates," and export prohibitions on "[g]oods and technology for the transport, ​telecommunications and energy sectors."[71] The European Union's sanctions also froze the assets and imposed travel restrictions against persons who "undermined Ukraine's territorial integrity, sovereignty, and independence."[72]

c. U.S. Sanctions Targeting Russian Oligarchs

The U.S. and E.U. sanction regimes did not target the entire Russian economy.[73] Instead, the sanctions designated key individuals, including several Russian oligarchs, and entities associated with important Russian policymakers.[74]

The term "oligarch" was popularized during the privatization of the Russian economy following the collapse of the Soviet Union.[75] Oligarchs are individuals who used political power to obtain control over former state assets in industries like oil, gas, timber, aluminum, and other natural resources.[76] Oligarchs formally assumed control over former state-owned companies through government auctions and "loans for shares" schemes.[77] Russians reportedly began referring to privatization as "prikhvatizatsiya" or "grabification," to describe a process whereby state authorities handed well-connected businesspersons and bankers control of previously government-controlled assets.[78]

​Following Vladimir Putin's election to the Russian presidency in 2000, existing power structures began to shift, facilitating the rise of a new generation of oligarchs.[79] Prior to becoming president, Putin promised to dismantle the existing class of oligarchs who prospered under his predecessor Boris Yeltsin.[80] In 2003, under Putin's direction, the government began to acquire some of Russia's wealthiest companies.[81] True to his word, Putin replaced the older generation of oligarchs with men from his inner circle and offered them valuable government contracts.[82] Loopholes in Russian law used to limit competition enabled these oligarchs to "build themselves into the state system," as they continued to gain access to state contracts.[83]

d. Arkady and Boris Rotenberg are Sanctioned by the United States

Brothers Arkady and Boris Rotenberg are among the oligarchs who have received billions of dollars from Putin-enabled government contracts.[84] Four days after President Obama's March 16, 2014 EO 13661 sanctioning "any individual or entity that is owned or controlled by, that has acted for or on behalf of, or that has provided material or other support to, a senior Russian government official," OFAC officially designated Arkady and Boris Rotenberg.[85] OFAC described Arkady and Boris Rotenberg as "members of the Russian leadership's inner circle."[86] This position made them both beneficiaries of a Russian economy that frequently enriched Putin loyalists.[87] That designation highlighted their close personal ties to President Putin. The Treasury announcement specifically stated:

​

Arkady Rotenberg and Boris Rotenberg have provided support to Putin's pet projects by receiving and executing high price contracts for the Sochi Olympic Games and state-controlled Gazprom. They have made billions of dollars in contracts for Gazprom and the Sochi Olympic Winter Olympics awarded to them by Putin. Both brothers have amassed enormous amounts of wealth during the years of Putin's rule in Russia. The Rotenberg brothers received approximately $7 billion in contracts for the Sochi Olympic Games and their personal wealth has increased by $2.5 billion the last two years alone.[88]

Arkady Rotenberg directly benefited from the annexation of Crimea, including through his companies receiving multi-million dollar contracts to build the Kerch Bridge and a railway linking Russia to the annexed region of Ukraine.[89] The Treasury Department imposed additional sanctions on Rotenberg-related entities under EO 13661 on April 28, 2014.[90] These sanctions included the following entities:

Invest CapitalBank and SMP Bank [which] are controlled by Arkady and Boris Rotenberg who were designated on March 20, 2014 pursuant to E.O. 13661 for acting for or on behalf of or materially assisting, sponsoring, or providing financial, material or technological support for, or goods and services to or in support of, a senior official of the Government of the Russian Federation.
Stroygazmontazh (SGM Group) [which] is a gas pipeline construction company owned or controlled by Arkady Rotenberg. Rotenberg created SGM Group in 2008 after acquiring multiple Gazprom contractors.[91]

On July 30, 2014, the European Union added Arkady Rotenberg to the E.U. sanctions list.[92] In September 2014, Italy's financial law enforcement agency seized ​almost $40 million of Arkady Rotenberg's assets, "including a luxury hotel in Rome and two villas in Sardinia."[93] Following the seizure, the Russian government endorsed legislation that would reimburse those whose overseas assets were seized by foreign authorities.[94] However, that legislation, known as "the Rotenberg law," never became law.[95]

i. Arkady Rotenberg

Arkady Rotenberg first met Vladimir Putin at the age of twelve, when they joined the same judo club.[96] After Arkady Rotenberg finished college, he worked as a judo trainer and continued to practice judo with Putin and others from the class.[97] Arkady Rotenberg then started a cooperative that organized sporting competitions and later became the general director of a professional judo club in St. Petersburg, where Putin served as vice-mayor of the city.[98] After Putin became President of Russia, Arkady and Boris Rotenberg invested in companies that serviced Gazprom, the major Russian gas company which is majority-owned by the Russian government.[99] The Rotenberg brothers also founded SMP Bank, which they used "to acquire stakes in construction, gas, and pipe companies."[100]

In 2008, Gazprom sold Arkady Rotenberg five construction and maintenance companies, which he merged into one company he named Stroigazmontazh ("SGM"). SGM became the chief contractor for Gazprom.[101] The company earned more than $2 billion in revenue during its first year of operations.[102] It handled construction work for the oil and gas industry, including onshore and offshore pipeline construction.[103]

Three years later, in March 2011, Gazprom sold Gazprom Burenie to Milasi Engineering Limited ("Milasi Engineering"), a Cypriot company owned by Arkady ​Rotenberg.[104] Gazprom Burenie subsequently became Gazprom's main drilling contractor and is currently one of the largest drilling contractors in Russia.[105] Gazprom Burenie's operations focus on oil and gas wells construction, including drilling, geological exploration, well construction, well overhaul, and inactive well recovery services.[106]

The Russian government awarded Gazprom Burenie and SGM several high-profile projects in Russia. For example, it contracted with SGM to build portions of the $12 billion Nord Stream undersea gas pipeline; the Russian government paid the Arkady Rotenberg-controlled company a profit margin of 30 percent for its work on the project.[107] The Russian government also awarded SGM a contract to build a 110-mile gas pipeline around the Russian city of Sochi, as part of the Russian government's 2014 Winter Olympics construction program.[108] The gas pipeline cost five times its original budget.[109] One estimate stated that 15 percent of the total Olympics budget went to Rotenberg-led projects.[110] In defending his personal relationship with President Putin, Arkady Rotenberg has argued "unlike a lot of other people, I don't have the right to make a mistake."[111] He has also asserted, "I have great respect for Putin and I consider him sent to our country from God."[112]

Gazprom Burenie has also played an important role in the Russian energy industry. Between 1997 and 2013, Gazprom Burenie completed the construction of 3,669 wells, drilling through more than 7 million meters of rock.[113]

In January 2015, the Russian government announced that Arkady Rotenberg, through SGM, would build the bridge connecting the Russian-annexed ​Crimean Peninsula to the Russian mainland.[114] In May 2018, the 12-mile bridge opened for traffic at a final cost of $3.7 billion.[115] According to news reports, the bridge opened six months ahead of schedule. The bridge reportedly can "carry up to 40,000 cars per day [and] its span is greater than that of Vasco da Gama in Portugal, previously the longest in Europe."[116] President Putin was on site to open the bridge to traffic.[117]

In September 2019, a news article stated that Gazprom had purchased 100 percent of SGM for 70 billion to 95 billion rubles, the equivalent of $1.1 billion to $1.5 billion.[118]

Forbes has estimated that Arkady Rotenberg is worth $2.8 billion.[119]

ii. Boris Rotenberg

Boris Rotenberg is also a childhood friend of Vladimir Putin.[120] Along with his brother Arkady, Boris Rotenberg and Putin have "sparred and trained in the same gym since they were teenagers in the 1960s."[121] Their former judo coach, Anatoly Rakhin, commented on the friendship between the brothers and Putin saying, "[Putin] didn't take the Petersburg boys to work with him because of their pretty eyes, but because he trusts people who are tried and true."[122] In 2001, Boris and Arkady Rotenberg founded SMP Bank.[123] The brothers then used the bank to acquire interests in important industries such as construction, gas, and gas pipelines.[124] By the mid-2000s, these acquisitions allowed them to become one of Russia's "main suppliers of large-diameter gas pipes."[125]

​When Boris Rotenberg's ex-wife, Irene Lamber, was asked to comment on the business impact of Putin's friendship with the Rotenberg brothers, she remarked, "[t]hey were friendly in childhood, and those relationships were never broken, so logically you can presume some sort of advice was given, at a minimum, and perhaps help here and there."[126]

Boris Rotenberg holds a Finnish passport and therefore "is not subject to European sanctions over Russia's role in Ukraine."[127] Boris Rotenberg secured Finnish citizenship after moving to the country with his ex-wife Irene in the late 1990s.[128] Although he is not directly subjected to the E.U's sanctions, several Nordic banks refused to process his payments because "European banks must comply with . . . U.S. sanctions in order to do business with American banks."[129] In response, Boris Rotenberg filed a discrimination suit against Nordea, Danske Bank, Handelsbanken, and OP Bank for violation of "his right to equal treatment as an EU citizen."[130] A Finnish court rejected the suit on January 13, 2020.[131]

Forbes estimates that Boris Rotenberg's net worth is $1.2 billion.[132]

e. Roman and Igor Rotenberg are Sanctioned by the United States

On February 12, 2015, the Wall Street Journal reported that Arkady and Boris Rotenberg sold lucrative assets to their children in an apparent effort to avoid sanctions by the United States.[133] The sales included Arkady selling his 79 percent stake in Gazprom Drilling LLC to his son Igor, and Boris's sale of the Finnish ​Langvik Congress Wellness Hotel to his son Roman.[134] The Rotenbergs described the sales as nothing more than a long-planned "generational change."[135]

i. Roman Rotenberg

In response to the transfers described above, on July 30, 2015, under EO 13661, OFAC added Roman Rotenberg to the list of sanctioned individuals.[136] A Treasury press release noted Roman Rotenberg was "linked to the provision of material support" to Boris Rotenberg.[137]

ii. Igor Rotenberg

On April 6, 2018, three years after sanctioning Arkady and Boris Rotenberg, OFAC also sanctioned Arkady's son Igor.[138] This round of sanctions targeted Russia's so-called "golden youth" and also included sanctions against Putin's son-in-law Kirill Shamalov.[139] Just prior to OFAC's imposition of sanctions, Forbes included Igor Rotenberg on its list of 259 new billionaires.[140] OFAC's announcement of the new sanctions credited Igor's designation to his activities in the Russian energy sector, noting that Igor had acquired significant assets from his father post-sanctions.[141]

From 2002 to 2003, Igor Rotenberg served as the deputy head "of the Property Department of the fuel and energy complex of the Ministry of Property and ​Land Relations" in Russia.[142] In 2003, Igor Rotenberg was named head of property management and transportation at the Russian Ministry of State Property.[143] In 2004, Igor Rotenberg was named vice-president of JSC Russian Railways, Russia's state-owned railroad company.[144]

Since 2006, Igor Rotenberg has served as Chairman of the Board of Directors for NPV Engineering.[145] NPV Engineering provides management and consulting services in Russia.[146] In 2010, Igor Rotenberg was named Chairman of Mosenergo, "the largest regional power generating company in the Russian Federation."[147] He was also named chairman of Gazprom Burenie, the key construction company beneficially owned by his father.[148]

After his placement on the U.S. sanctions list in 2014, Arkady Rotenberg reportedly transferred certain assets to his son Igor.[149] According to reports, Igor Rotenberg now owns "79 percent of drilling company Gazprom Burenie; 28 percent of road construction company Mostotrest; and 33 percent of TPS Real Estate Holding."[150]

Forbes estimates that Igor Rotenberg's net worth is $1.1 billion.[151]

As explained below, despite the imposition of U.S. sanctions on Arkady and Boris Rotenberg in March 2014, Roman Rotenberg in July 2015, and Igor Rotenberg in April 2018, evidence suggests that the Rotenbergs continued to do business with some U.S. parties.

  1. ↑ Jack Lew, Secretary, U.S. Dep't of Treasury, Remarks on the Evolution of Sanctions and Lessons for the Future at the Carnegie Endowment for International Peace (Mar. 30, 2016), https://www.treasury.gov/press-center/press-releases/pages/j10398.aspx.
  2. ↑ Kathy Gilsinan, A Boom Time for U.S. Sanctions, Atlantic (May 3, 2019), https://www.theatlantic.com/politics/archive/2019/05/why-united-states-uses-sanctions-somuch/588625/.
  3. ↑ Carol Morello, Trump administration's use of sanctions draws concern, Wash. Post (Aug. 5, 2018), https://www.washingtonpost.com/world/national-security/trump-administrations-use-of-sanctionsdraws-concern/2018/08/05/36ec7dde-9402-11e8-a679-b09212fb69c2_story.html.
  4. ↑ Id.
  5. ↑ U.S. Dep't of Treasury, Act of Congress Establishing the Treasury Department, https://www.treasury.gov/about/history/Pages/act-congress.aspx; U.S. Dep't of Treasury, Role of the Treasury, https://home.treasury.gov/about/general-information/role-of-the-treasury.
  6. ↑ U.S. Dep't of Treasury, Role of the Treasury, https://home.treasury.gov/about/generalinformation/role-of-the-treasury.
  7. ↑ Id.
  8. ↑ Id.
  9. ↑ 31 U.S.C. § 312.
  10. ↑ Id.; U.S. Dep't of Treasury, About: Terrorism and Financial Intelligence, https://www.treasury.gov/about/organizational-structure/offices/Pages/Office-of-Terrorism-and-Financial-Intelligence.aspx.
  11. ↑ Id.
  12. ↑ U.S. Dep't of Treasury, Terrorism and Financial Intelligence: Office of Foreign Assets Control (OFAC), https://www.treasury.gov/about/organizational-structure/offices/Pages/Office-of-Foreign-Assets-Control.aspx.
  13. ↑ Trading with the Enemy Act of 1917, Pub. L. No. 65-61, 40 Stat. 411, codified as amended at 50 U.S.C. § 4303 (2018).
  14. ↑ Christopher A. Casey et al., Cong. Research Serv., R45618, The International Emergency Economic Powers Act: Origins, Evolution, and Use Summary (2019), https://www.crs.gov/reports/pdf/R45618.
  15. ↑ International Emergency Economic Powers Act of 1977, Pub. L. No. 95-459, 91 Stat. 1626, codified as amended at 50 U.S.C. § 1701 (2018).
  16. ↑ Omnibus Trade and Competitiveness Act of 1988, Pub. L. No. 100-418, 102 Stat. 1107, codified at 50 U.S.C. § 1702 (2001); See Bruce Craig, Sleeping with the Enemy? OFAC Rules and First Amendment Freedoms, Perspectives on History (May 1, 2004), https://www.historians.org/publications-and-directories/perspectives-on-history/may-2004/sleeping-with-the-enemy-ofac-rules-and-first-amendment-freedoms.
  17. ↑ Omnibus Trade and Competitiveness Act of 1988, Pub. L. No. 100-418, 102 Stat. 1107, codified at 50 U.S.C. § 1702 (2001).
  18. ↑ Id.
  19. ↑ National Defense Authorization Act of 2017, Pub. L. No. 114-328, 130 Stat. 2000, codified at 22 U.S.C. § 2656.
  20. ↑ Id.
  21. ↑ Dianne E. Rennack, Cong. Research Serv., IF10576, The Global Magnitsky Human Rights Accountability Act (2018), https://www.crs.gov/reports/pdf/IF10576.
  22. ↑ Press Release, U.S. Dep't of Treasury, Testimony of John E. Smith, Director of the Office of Foreign Assets Control, (Nov. 30, 2017), https://www.treasury.gov/press-center/press-releases/Pages/sm0226.aspx.
  23. ↑ Id.
  24. ↑ Id.
  25. ↑ James Kostiw, OFAC Launches New SDN Search Tool, U.S. Dep't of Treasury, (Mar. 13, 2013), https://www.treasury.gov/connect/blog/Pages/OFAC-Launches-New-SDN-Search-Tool.aspx.
  26. ↑ U.S. Dep't of Treasury, Specially Designated Nationals and Blocked Persons List (SDN) Human Readable Lists, (Jan. 21, 2020), https://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx.
  27. ↑ Id.
  28. ↑ U.S. Dep't of Treasury Basic Information on OFAC and Sanctions, https://www.treasury.gov/resource-center/faqs/Sanctions/Documents/faq_all.html.
  29. ↑ Exec. Order No. 13,685, 79 Fed. Reg. 77,357 (Dec. 19, 2014); See also Exec. Order No. 13,662 31 C.F.R. § 589 (2014).
  30. ↑ Exec. Order No. 13,661 31 C.F.R. § 589 (2014).
  31. ↑ U.S. person means "any United States citizen or alien admitted for permanent residence in the United States, and any corporation, partnership, or other organization organized under the law of the United States." 22 U.S.C. § 6010; U.S. Dep't of Treasury, Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked (2014), https://www.treasury.gov/resource-center/sanctions/Documents/licensing_guidance.pdf.
  32. ↑ U.S. Dep't of Treasury, Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked (2014), https://www.treasury.gov/resource-center/sanctions/Documents/licensing_guidance.pdf.
  33. ↑ James Kostiw, OFAC Launches New SDN Search Tool, U.S. Dep't of Treasury, (Mar. 13, 2013), https://www.treasury.gov/connect/blog/Pages/OFAC-Launches-New-SDN-Search-Tool.aspx.
  34. ↑ U.S. Dep't of Treasury, Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked (2014), https://www.treasury.gov/resource-center/sanctions/Documents/licensing_guidance.pdf.
  35. ↑ Id.
  36. ↑ Exec. Order No. 13,660 31 C.F.R. § 589 (2014).
  37. ↑ Exec. Order No. 13,661 31 C.F.R. § 589 (2014).
  38. ↑ Press Release, U.S. Dep't of Treasury, Treasury Sanctions Russian Officials, Members Of The Russian Leadership's Inner Circle, And An Entity For Involvement In The Situation In Ukraine, (Mar. 20, 2014), https://www.treasury.gov/press-center/press-releases/Pages/j123331.aspx.
  39. ↑ Id.
  40. ↑ EU restrictive measures in response to the crisis in Ukraine, Council of the European Union (Dec. 19, 2019), https://www.consilium.europa.eu/en/policies/sanctions/ukraine-crisis/.
  41. ↑ Steven Lee Myers & Ellen Barry, Putin Reclaims Crimea for Russia and Bitterly Denounces the West, N. Y. Times (Mar. 18, 2014), https://www.nytimes.com/2014/03/19/world/europe/ukraine.html.
  42. ↑ Vladimir Isachenkov and Maria Danilova, Roots and Consequences of Ukraine's Violence, Associated Press (Feb. 20, 2013), https://web.archive.org/web/20140221000303/http://hosted.ap.org/dynamic/stories/E/EU_UKRAINE_NEWS_GUIDE?SITE=AP&SECTION=HOME&TEMPLATE=DEFAULT.
  43. ↑ William Booth, Ukraine's parliament votes to oust president; former prime minister is freed from prison, Wash. Post (Feb. 22, 2014), https://www.washingtonpost.com/world/europe/ukraines-yanukovych-missing-as-protesters-take-control-of-presidential-residence-in-kiev/2014/02/22/802f7c6c-9bd2-11e3-ad71-e03637a299c0_story.html?utm_term=.af74a8230f13.
  44. ↑ Andrew E. Kramer, Ukraine's Ex-President Is Convicted of Treason, N.Y. Times (Jan. 24, 2019), https://www.nytimes.com/2019/01/24/world/europe/viktor-yanukovych-russia-ukraine-treason.html.
  45. ↑ Cory Welt, Cong. Research Serv., R45008, Ukraine: Background, Conflict with Russia, and U.S. Policy, 9 (2019), https://www.crs.gov/reports/pdf/R45008.
  46. ↑ Catherine Boyle, Crimea referendum: Why it's so important, CNBC (Mar. 14, 2014), https://www.cnbc.com/2014/03/14/crimea-referendum-why-its-so-important.html; Charles King, Crimea, the Tinderbox, N. Y. Times (Mar. 1, 2014), https://www.nytimes.com/2014/03/03/opinion/crimea-the-tinderbox.html?searchResultPosition=4.
  47. ↑ Alissa de Carbonnel & Luke Baker, Crimea votes to join Russia, Obama orders sanctions, Reuters (Mar. 5, 2014), https://www.reuters.com/article/us-ukraine-crisis/crimea-votes-to-join-russia-obama-orders-sanctions-idUSBREA1Q1E820140306.
  48. ↑ Steven Lee Myers & Ellen Barry, Putin Reclaims Crimea for Russia and Bitterly Denounces the West, N. Y. Times (Mar. 18, 2014), https://www.nytimes.com/2014/03/19/world/europe/ukraine.html?module=inline.
  49. ↑ Id.
  50. ↑ Id.
  51. ↑ Id.
  52. ↑ David Herszenhorn & Andrew Kramer, Ukraine Plans to Withdraw Troops From Russia-Occupied Crimea, N. Y. Times (Mar. 19, 2014), https://www.nytimes.com/2014/03/20/world/europe/crimea.html.
  53. ↑ Cory Welt, Cong. Research Serv., R45008, Ukraine: Background, Conflict with Russia, and U.S. Policy, 9 (2019), https://www.crs.gov/reports/pdf/R45008.
  54. ↑ Id.
  55. ↑ Id. at 9-10
  56. ↑ Aleksandar Vasovic & Adrian Croft, U.S., EU set sanctions as Putin recognizes Crimea "sovereignty", Reuters (Mar. 16, 2014), https://www.reuters.com/article/us-ukraine-crisis/u-s-eu-set-sanctions-as-putin-recognizes-crimea-sovereignty-idUSBREA1Q1E820140317.
  57. ↑ Cory Welt et. al, Cong. Research Serv., R45415, U.S. Sanctions on Russia, 7 (2020), https://www.crs.gov/reports/pdf/R45415.
  58. ↑ U.S. Dep't of Treasury, Sanctions List Search, https://sanctionssearch.ofac.treas.gov/.
  59. ↑ Dan Roberts & Ian Traynor, US and EU impose sanctions and warn Russia to relent in Ukraine standoff, The Guardian (Mar. 6, 2014), https://www.theguardian.com/world/2014/mar/06/us-eu-sanctions-obama-russia-ukraine-crimea; See also U.S. Dep't of Treasury, Ukraine/Russia-Related Sanctions Program 3 (2016), https://www.treasury.gov/resource-center/sanctions/Programs/Documents/ukraine.pdf.
  60. ↑ Exec. Order No. 13,660 31 C.F.R. § 589 (2014).
  61. ↑ Alissa de Carbonnel and Luke Baker, Crimea votes to join Russia, Obama orders sanctions, Reuters (Mar. 5, 2014), https://www.reuters.com/article/us-ukraine-crisis/crimea-votes-to-join-russia-obama-orders-sanctions-idUSBREA1Q1E820140306.
  62. ↑ Press Release, The White House, Statement by the Press Secretary on Ukraine, (March 16, 2014), https://obamawhitehouse.archives.gov/the-press-office/2014/03/16/statement-press-secretary-ukraine.
  63. ↑ Exec. Order No. 13,661 31 C.F.R. § 589 (2014).
  64. ↑ Id.
  65. ↑ Press Release, U.S. Dep't of Treasury, Treasury Sanctions Russian Officials, Members Of The Russian Leadership's Inner Circle, And An Entity For Involvement In The Situation In Ukraine, (Mar. 20, 2014), https://www.treasury.gov/press-center/press-releases/Pages/j123331.aspx.
  66. ↑ Exec. Order No. 13,662, 31 C.F.R. § 589 (2014); Exec. Order No. 13,685, 79 Fed. Reg. 77,357 (Dec. 19, 2014).
  67. ↑ Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014, Pub. L. No. 113-95, 22 U.S.C. §8901; Ukraine Freedom Support Act of 2014, Pub. L. No. 113-272, 22 U.S.C. § 8921.
  68. ↑ Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014, Pub. L. No. 113-95, 22 U.S.C. §8901; Cory Welt et. al, Cong. Research Serv., R45415, U.S. Sanctions on Russia, 13 (2020), https://www.crs.gov/reports/pdf/R45415.
  69. ↑ Cory Welt et. al, Cong. Research Serv., R45415, U.S. Sanctions on Russia, 13 (2020), https://www.crs.gov/reports/pdf/R45415.
  70. ↑ EU restrictive measures in response to the crisis in Ukraine, Council of the European Union (Dec. 19, 2019), https://www.consilium.europa.eu/en/policies/sanctions/ukraine-crisis/.
  71. ↑ The EU non-recognition policy for Crimea and Sevastopol: Fact Sheet, European Union External Action (Dec. 12, 2017), https://eeas.europa.eu/headquarters/headquarters-Homepage/37464/eu-non-recognition-policy-crimea-and-sevastopol-fact-sheet_en.
  72. ↑ EU restrictive measures in response to the crisis in Ukraine, Council of the European Union (Dec. 19, 2019), https://www.consilium.europa.eu/en/policies/sanctions/ukraine-crisis/.
  73. ↑ Cory Welt, Cong. Research Serv., R45008, Ukraine: Background, Conflict with Russia, and U.S. Policy, 36 (2019), https://www.crs.gov/reports/pdf/R45008.
  74. ↑ Id.; Andrew Higgins, Oleg Matsnev, & Ivan Nechepurenko, Meet the 7 Russian Oligarchs Hit by the New U.S. Sanctions, N. Y. Times (Apr. 6, 2018), https://www.nytimes.com/2018/04/06/world/europe/russian-oligarchs-sanctions.html.
  75. ↑ Z. Byron Wolf, Russia's oligarchs are different from other billionaires, CNN (Apr. 6, 2018), https://www.cnn.com/2018/04/06/politics/oligarch-russia-billionaires-government-putin-sanctions/index.html.
  76. ↑ Id.
  77. ↑ Adam Taylor, How the 2003 Arrest of the Richest Man in Russia Changed Everything-And What Happens Next, Business Insider (Oct. 24, 2013), https://www.businessinsider.com/ten-years-after-mikhail-khodorkovskys-arrest-2013-10. Under the "loans for shares" plan, Kremlin-favored banks would lend the government money in exchange for the opportunity to buy cheap shares in government assets. The banks would hold the shares in trust, giving the government the opportunity to repay the loan. In most cases, the banks would sell the shares within two years on the open market, creating windfall profits. Alessandra Stanley, Russian Banking Scandal Poses Threat to Future of Privatization, N. Y. Times (Jan. 28, 1996), https://www.nytimes.com/1996/01/28/world/russian-banking-scandal-poses-threat-to-future-of-privatization.html?pagewanted=all&src=pm.
  78. ↑ Alessandra Stanley, Russian Banking Scandal Poses Threat to Future of Privatization, N. Y. Times (Jan. 28, 1996), https://www.nytimes.com/1996/01/28/world/russian-banking-scandal-poses-threat-to-future-of-privatization.html?pagewanted=all&src=pm.
  79. ↑ Andrew Meier, Who Fears a Free Mikhail Khodorkovsky?, N. Y. Times (Nov. 18, 2009), https://www.nytimes.com/2009/11/22/magazine/22khodorkovsky-t.html.
  80. ↑ Steven Meyers, Jo Becker & Jim Yardley, Private Bank Fuels Fortunes of Putin's Inner Circle, N. Y. Times (Sept. 27, 2014), https://www.nytimes.com/2014/09/28/world/europe/it-pays-to-be-putins-friend-.html?module=inline.
  81. ↑ Andrew Meier, Who Fears a Free Mikhail Khodorkovsky?, N. Y. Times (Nov. 18, 2009), https://www.nytimes.com/2009/11/22/magazine/22khodorkovsky-t.html.
  82. ↑ Steven Meyers, Jo Becker & Jim Yardley, Private Bank Fuels Fortunes of Putin's Inner Circle, N. Y. Times (Sept. 27, 2014), https://www.nytimes.com/2014/09/28/world/europe/it-pays-to-be-putins-friend-.html?module=inline.
  83. ↑ Joshua Yaffa, Putin's Shadow Cabinet and The Bridge to Crimea, New Yorker (May 22, 2017), https://www.newyorker.com/magazine/2017/05/29/putins-shadow-cabinet-and-the-bridge-to-crimea.
  84. ↑ Id.
  85. ↑ Id.; See also Exec. Order No. 13,661 31 C.F.R. § 589 (2014).
  86. ↑ Press Release, U.S. Dep't of Treasury, Treasury Sanctions Russian Officials, Members Of The Russian Leadership's Inner Circle, And An Entity For Involvement In The Situation In Ukraine, (Mar. 20, 2014), https://www.treasury.gov/press-center/press-releases/pages/j123331.aspx.
  87. ↑ Steven Meyers, Jo Becker & Jim Yardley, Private Bank Fuels Fortunes of Putin's Inner Circle, N. Y. Times (Sept. 27, 2014), https://www.nytimes.com/2014/09/28/world/europe/it-pays-to-be-putins-friend-.html?module=inline.
  88. ↑ Press Release, U.S. Dep't of Treasury, Treasury Sanctions Russian Officials, Members Of The Russian Leadership's Inner Circle, And An Entity For Involvement In The Situation In Ukraine, (Mar. 20, 2014), https://www.treasury.gov/press-center/press-releases/pages/j123331.aspx.
  89. ↑ Id.; see also Christopher Harress, Moscow to Build Bridge From Russian Mainland to Crimea Across Kerch Strait, Int'l Bus. Times (Jun. 30, 2015), https://www.ibtimes.com/moscow-build-bridge-russian-mainland-crimea-across-kerch-strait-1990907.
  90. ↑ Press Release, U.S. Dep't of the Treasury, Announcement of Additional Treasury Sanctions on Russian Government Officials and Entities (Apr. 28, 2014), https://www.treasury.gov/press-center/press-releases/Pages/.
  91. ↑ Id.
  92. ↑ 2014 O.J. (L 226) 17, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2014:226:FULL&from=EN#page25. As a Finnish citizen, Boris Rotenberg avoided inclusion on the European list. Anne Kauranen & Jussi Rosendahl, Russian oligarch under U.S. sanctions files suit against Nordic banks, Reuters (Oct. 22, 2018), https://www.reuters.com/article/us-finland-russia-sanctions/russian-oligarch-under-u-s-sanctions-files-suit-against-nordic-banks-idUSKCN1MW1AJ.
  93. ↑ James Politi & Courtney Weaver, Italy seizes Putin ally Arkady Rotenberg's property assets, Fin. Times (Sept. 23, 2014), https://www.ft.com/content/f1293172-4340-11e4-be3f-00144feabdc0; See also Italy Freezes Assets of Sanctioned Russian Billionaire Arkady Rotenberg, Moscow Times (Sept. 23, 2014), https://themoscowtimes.com/articles/italy-freezes-assets-of-sanctioned-russian-billionaire-arkady-rotenberg-39683.
  94. ↑ Italy Freezes Assets of Sanctioned Russian Billionaire Arkady Rotenberg, Moscow Times (Sept. 23, 2014), https://themoscowtimes.com/articles/cabinet-wants-to-compensate-russian-victims-of-illegal-asset-seizures-abroad-40020.
  95. ↑ Joshua Yaffa, Putin's Shadow Cabinet and The Bridge to Crimea, New Yorker (May 22, 2017), https://www.newyorker.com/magazine/2017/05/29/putins-shadow-cabinet-and-the-bridge-to-crimea.
  96. ↑ Id.
  97. ↑ Id.
  98. ↑ Id.
  99. ↑ Id.
  100. ↑ Id.
  101. ↑ Id.
  102. ↑ Id.
  103. ↑ SMG Group of Companies, Stroygazmontazh, http://www.ooosgm.com/company/structure/.
  104. ↑ Gazprom, Financial Report 2011: Reaching new Horizons 58 (2011), https://www.gazprom.com/f/posts/43/588793/financial-report-2011-eng.pdf.
  105. ↑ Company Profile: Gazprom Bureniye, Russian Drilling Company, Gazprom Bureniye, https://www.burgaz.ru/landing/.
  106. ↑ Id.
  107. ↑ Gleb Bryanski, Putin's judo partner jumps in Russia's rich list, Reuters (Feb. 13, 2011), https://www.reuters.com/article/russia-rich/putins-judo-partner-jumps-in-russias-rich-list-idUSLDE71C02X20110214; Aviezer Tucker, The New Power Map, Foreign Affairs (Dec. 19, 2012), https://www.foreignaffairs.com/articles/north-america/2012-12-19/new-power-map.
  108. ↑ Thomas Grove, Special Report: Russia's $50 billion Olympic gamble, Reuters (Feb. 21, 2013), https://www.reuters.com/article/us-russia-sochi/special-report-russias-50-billion-olympic-gamble-idUSBRE91K04M20130221; Dzhubga-Lazarevskoe-Sochi gas pipeline, Stroygazmontazh, http://www.ooosgm.com/projects/construction/gazoprovod-dzhubga-lazarevskoe-sochi/.
  109. ↑ Anna Pukas, Sochi: Is it Russia's disaster Winter Olympics?, Express (Feb. 3, 2014), https://www.express.co.uk/news/world/457632/Sochi-Is-it-Russia-s-disaster-Winter-Olympics.
  110. ↑ Neil MacFarquhar & Ivan Nechepurenko, Putin's Bridge to Crimea May Carry More Symbolism Than Traffic, N. Y. Times (Nov. 11, 2017), https://www.nytimes.com/2017/11/11/world/europe/vladimir-putin-russia-crimea-bridge.html.
  111. ↑ Joshua Yaffa, Putin's Shadow Cabinet and the Bridge to Crimea, New Yorker (May 22, 2017), https://www.newyorker.com/magazine/2017/05/29/putins-shadow-cabinet-and-the-bridge-to-crimea.
  112. ↑ Id.
  113. ↑ History of the Company, Gazprom Burenie, http://www.burgaz.ru/company/about/history/.
  114. ↑ Joshua Yaffa, Putin's Shadow Cabinet and the Bridge to Crimea, New Yorker (May 22, 2017), https://www.newyorker.com/magazine/2017/05/29/putins-shadow-cabinet-and-the-bridge-to-crimea.
  115. ↑ Andre Roth, Putin opens 12-mile bridge between Crimea and Russian mainland, Guardian (May 15, 2018), https://www.theguardian.com/world/2018/may/15/putin-opens-bridge-between-crimea-and-russian-mainland.
  116. ↑ Id.
  117. ↑ Id.
  118. ↑ Bne IntelliNews, Russia's Gazprom Buys Out its Biggest Subcontractor, The Moscow Times (Sept. 27, 2019), https://www.themoscowtimes.com/2019/09/27/russias-gazprom-buys-out-its-biggest-subcontractor-a67475.
  119. ↑ Real Time Net Worth, No. 877, Arkady Rotenberg, Forbes, https://www.forbes.com/profile/arkady-rotenberg/#671573b62baa.
  120. ↑ Simon Shuster, Putin's Powerful Friends Rally Around Russian President Despite Sanctions, Time (Mar. 27, 2014), https://time.com/38632/putin-friends-rally-around-him/.
  121. ↑ Id.
  122. ↑ Id.
  123. ↑ Joshua Yaffa, Putin's Shadow Cabinet and the Bridge to Crimea, New Yorker (May 22, 2017), https://www.newyorker.com/magazine/2017/05/29/putins-shadow-cabinet-and-the-bridge-to-crimea.
  124. ↑ Id.
  125. ↑ Id.
  126. ↑ Id.
  127. ↑ Anne Kauranen & Jussi Rosendahl, Russian oligarch under U.S. sanctions files suit against Nordic banks, Reuters (Oct. 22, 2018), https://www.reuters.com/article/us-finland-russia-sanctions/russian-oligarch-under-u-s-sanctions-files-suit-against-nordic-banks-idUSKCN1MW1AJ.
  128. ↑ Joshua Yaffa, Putin's Shadow Cabinet and the Bridge to Crimea, New Yorker (May 22, 2017), https://www.newyorker.com/magazine/2017/05/29/putins-shadow-cabinet-and-the-bridge-to-crimea.
  129. ↑ Anne Kauranen & Jussi Rosendahl, Russian oligarch under U.S. sanctions files suit against Nordic banks, Reuters (Oct. 22, 2018), https://www.reuters.com/article/us-finland-russia-sanctions/russian-oligarch-under-u-s-sanctions-files-suit-against-nordic-banks-idUSKCN1MW1AJ.
  130. ↑ Anne Kauranen & Tarmo Virki, Finnish court rejects Rotenberg's suit against Nordic banks, Reuters (Jan. 13, 2020), https://www.reuters.com/article/finland-russia-sanctions/finnish-court-rejects-rotenbergs-suit-against-nordic-banks-idUSL8N291260.
  131. ↑ Id.
  132. ↑ Real Time Net Worth, No. 1941, Boris Rotenberg, Forbes (Feb. 26, 2020), https://www.forbes.com/profile/boris-rotenberg/#49cf806c126a.
  133. ↑ Rachel Ensign, Russian Asset Sales Muddy Sanction Compliance, Wall St. J. (Feb. 12, 2015), https://www.wsj.com/articles/russian-asset-sales-muddy-sanction-compliance-1423784903.
  134. ↑ Id.; see also Bill Chappel, U.S. Hits Russian Oligarchs And Officials With Sanctions Over Election Interference, NPR (Apr. 6, 2018), https://www.npr.org/sections/thetwo-way/2018/04/06/600083466/u-s-hits-russian-oligarchs-and-officials-with-sanctions-over-election-interferen.
  135. ↑ Rachel Ensign, Russian Asset Sales Muddy Sanction Compliance, Wall St. J. (Feb. 12, 2015), https://www.wsj.com/articles/russian-asset-sales-muddy-sanction-compliance-1423784903.
  136. ↑ Press Release, U.S. Dep't of Treasury, Ukraine-related Designations; Sectoral Sanctions Identifications; Dote d'Ivoire Designation Removals; Issuance of an Important Crimea Sanctions Advisory, (Jul. 30, 2015), https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20150730.aspx.
  137. ↑ Press Release, U.S. Dep't of Treasury, Treasury Sanctions Individuals and Entities Involved in Sanctions Evasion Related To Russia and Ukraine, (Jul. 30, 2015), https://www.treasury.gov/press-center/press-releases/Pages/j10133.aspx.
  138. ↑ Press Release, U.S. Dep't of Treasury, Treasury Designates Russian Oligarchs, Officials, and Entities in Response to Worldwide Malign Activity, (Apr. 6, 2018), https://home.treasury.gov/news/press-releases/sm0338.
  139. ↑ Anders Aslund, With New Sanctions the US Treasury Goes after Putin's Inner Circle, Atlantic Council, (Apr. 6, 2018), https://www.atlanticcouncil.org/blogs/new-atlanticist/with-new-sanctions-the-us-treasury-goes-after-putin-s-inner-circle/.
  140. ↑ Chase Peterson-Withorn, Meet the World's 259 Newest Billionaires, Forbes (Mar. 6, 2018), https://www.forbes.com/sites/chasewithorn/2018/03/06/meet-the-worlds-259-newest-billionaires-francois-bettencourt-meyers-lynsi-snyder #502c52683ee9.
  141. ↑ Press Release, U.S. Dep't of Treasury, Treasury Designates Russian Oligarchs, Officials, and Entities in Response to Worldwide Malign Activity, (Apr. 6, 2018), https://home.treasury.gov/news/press-releases/sm0338.
  142. ↑ Yevgeny Gusev, The Kings of State Procurement, Henry Jackson Soc. 8 (May 2017), http://henryjacksonsociety.org/wp-content/uploads/2018/06/1705-The-Kings-of-State-Procurement.pdf.
  143. ↑ Id.
  144. ↑ Id.
  145. ↑ Id. at 8-9.
  146. ↑ Press Release, U.S. Dep't of Treasury, Treasury Designates Russian Oligarchs, Officials, and Entities in Response to Worldwide Malign Activity, (Apr. 6, 2018), https://home.treasury.gov/news/press-releases/sm0338.
  147. ↑ Arkady Rotenberg: We live in conditions of tough competition, but it doesn't scare us, Interfax (Oct. 30, 2014), http://www.interfax.com/interview.asp?id=547794; About the Company, Mosenergo, https://mosenergo.gazprom.com/about/.
  148. ↑ 2018 Billionares Net Worth, No. 1999, Igor Rotenberg, Forbes (Mar. 6, 2018), https://www.forbes.com/profile/igor-rotenberg/#393b87e51ef8.
  149. ↑ Rachel Louise Ensign, Russian Asset Sales Muddy Sanction Compliance, Wall St. J. (Feb. 12, 2015), https://www.wsj.com/articles/russian-asset-sales-muddy-sanction-compliance-1423784903.
  150. ↑ Stephen Grey & Elizabeth Piper, Rising stars among children of Russia's elite, Reuters (Nov. 10, 2015), https://www.reuters.com/article/us-russia-capitalism-sons/rising-stars-among-children-of-russias-elite-idUSKCNOSZ1DP20151110.
  151. ↑ 2018 Billionares Net Worth, No. 1999 Igor Rotenberg, Forbes (Mar. 6, 2018), https://www.forbes.com/profile/igor-rotenberg/#393b87e51ef8.
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