In the dead of night on January 29, 2018, the Department of the Treasury published a list of senior political figures and oligarchs in Russia on a U.S. government website. With just 11 minutes to spare before a congressional deadline, American financial regulators had satisfied one of the requirements of Congress’ Countering America’s Adversaries Through Sanctions Act. It was a slapdash effort; names on the list appeared to have been copy-and-pasted from the Forbes billionaires report and from public directories of Russian government staff. But the list nonetheless informed a Treasury sanctions package released three months later targeting prominent Russians
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