The long-anticipated 'Kremlin Report' by the US Department of Treasury includes 210 names of Russia's richest tycoons, officials close to President Vladimir Putin, and CEOs of largest state corporations, but no sanctions on any of these people are actually imposed. 

96 people on the list are from the business community with a net worth of more than $1bn each and are now Kremlin-linked by the reported so potentially marked for US sanctions. The report also lists almost the entire top tier of Russia's political class. 

The list was met with bemusement in Moscow as the list of oligarchs almost exactly matches last year’s Russian Forbes magazine rich list of Russian businessmen worth more than $1bn.

The whole sale copying of the rich lists belies the point of the report, which was to identify those oligarchs that had made their money thanks to their close connections to Putin rather than simply a list of the top businessmen.

“To determine the list of oligarchs, the Department of the Treasury enumerated those individuals who, according to reliable public sources, have an estimated net worth of $1 billion or more. Those individuals who meet this criterion are listed in Appendix 2 of this report,” the Department of the Treasury said in its report.

Taking this blunderbuss approach means many well respected Russian businessmen have been caught up in the list that will likely impare their ability to raise money abroad.

At the top of the Forbes list is Leonid Mikhelson, the owner of independent gas producer Novatek, who is worth $18.4bn and certainly could not operate or be successful without the patronage of the Kremlin. But second on the list is Alexey Mordashov, the owner of Severstal steel mill, who is worth $17.5bn and is widely respected as being simply a good businessman and doesn't rely on the Kremlin for his fortune. He is followed by Vladimir Lisin, owner of Novolipetsk Meatllurgical Kombinat (NLMK), another steel mill and another clean and respectable businessman.

Indeed, the first really dubious name on the Forbes list is Gennady Timchenko at number four who is worth $16bn and is the first stoligarch, the businessmen who owe their fortunes almost entire due to Putin’s personal patronage.

Other men high up on the list are well known for being no friends of Putin. Vagit Alekperov, the owner of Russia’s largest independent oil producer Lukoil, who is worth $14.5bn and is at six on the list, is terrified of being attacked and taken over by the Kremlin, according to bne sources in the company. And Mikhail Fridman, the owner of the Alfa Group and worth $14.4bn, has left Russia despite being explicitly and publically being told by Putin to keep his money and invest it at home. Fridman is no angle but he is no friend of Putin’s either.

However, despite previous concerns no immediate sanctions are being introduced, in what is current more of a name and shame exercise. Moreover, there is a classified part of the list that was not released that reportedly contains more details of each man’s wealth and their personal connections to Putin.

The CEO of Russia's largest bank German Gref, the head of Russia's largest oil company Rosneft Igor Sechin, the head of Russia's gas giant Gazprom Alexei Miller the head of Russia's second-largest state controlled bank VTB Andrei Kostin of VTB, are among the state-affiliated top managers listed.

Here too there is a contrast. Sberbank has become an investors’ darling and Russia’s top “tourist stock” – if you are going to buy one Russian stock, because you to track the MSCI Russia or EM index and have to have some exposure, then Sberbank is the name you buy. Gref has won wide praise for taking the retail banking monster in hand and turning it into not only the best bank in Russia but one of the most dynamic banks in Europe.

Sechin on the other hand is about as much of a stoligarch as it is possible to be. He is widely considered the third most powerful man in Russia and is clearly above the law. In the recent corruption trial of Economics Minister Alexey Ulyukayev, Sechin ignored multiple court orders to show and testify as a witness, as it was Sechin that handed Ulyukayev a bag of money. Sechin simply said he was “too busy” to come to court.

The list also has the names of 114 senior politicians and members of the Russian leadership. All of the presidential administration, the cabinet, a number of presidential advisers and the Prime Minister Dmitry Medvedev are also included in the list. 

Among them are First Deputy Prime Minister Igor Shuvalov, Deputy Prime Ministers Sergey Prikhodko, Alexander Khloponin, Vitaly Mutko, Arkady Dvorkovich, Olga Golodets, Dmitry Kozak and Dmitry Rogozin, and other 22 ministers, including Foreign Minister Sergey Lavrov and Defence Minister Sergey Shoigu, Tass reports.

Presidential Administration Chief Anton Vaino and Kremlin Spokesman Dmitry Peskov were also included on the list.

The report was mandated by the Congress under the new round of sanctions sighed off on in August 2017. As reported by bne IntelliNews, the imminent publication of the list put Russia’s elite in a frenzy.

After the sanctions list update on January 26 the US Treasury is taking a pause, possibly to bring the more damaging information out closer to the presidential election set for March 2018.

Heather Nauert, the state department spokesperson, said the Donald Trump administration had notified Congress on January 29 the legislation in place was already helping to limit Russian defence sales and there was no need at the present time to impose further sanctions under the CAATSA regime (Countering Adversaries Through Sanctions Act). There are much more damaging sanctions that could wreck Russia’s ability to do business in the US and badly damage it in Europe if adopted in their entirety.

“This is not a sanctions list,” the Treasury Department stressed. “No restrictions are slapped on the individuals on the list. The inclusion of these individuals on the list does not create any obstacles for business contacts of US citizens provided that they are not subject to sanctions.”

While the oligarchs have not been sanctioned as part of the Kremlin report briefing the State Department went out of its way to emphasis Russia’s defence sector may be targeted.

New sanctions against Russia, if they are introduced, will affect the partners of the Russian defence industry complex and its intelligence services, a representative with the US Department of State told a TASS correspondent.

"Starting today, the State Department can begin imposing sanctions under Section 231 of the Countering America’s Adversaries Through Sanctions Act, or CAATSA, for significant transactions with the Russian defence or intelligence sector," the representative said. "When and if we have sanctions to announce, we will do so. Generally speaking, should sanctions be imposed, they would primarily be on non-Russian entities that are responsible for significant transactions with Russia’s defence and intelligence sector," the official said.