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Dear friends and colleagues,


As we look ahead to 2018, we’re confronted by both challenges and opportunities. Addressed in our final newsletter of 2017 are mounting US sanctions, tightening regulations, the emergence of new financial technologies; which pose just some of the compliance challenges on our horizon.


We wish you easy reading, happy holidays, and a prosperous new year.


The Sqope Team.






In its latest round of sanctions against Russia, the US government enacted the bill ‘Countering America’s Adversaries Through Sanctions’ (CAATSA) in August 2017. While the law both expands and entrenches punitive measures already in place, section 241 calls for a report to identify and list Russia’s top powerbrokers within 180 days – the prospect of which has generated significant media attention focusing on the consternation of the country’s elite over their future sanctions exposure.  


“The Kremlin Report”


Specifically, section 241 of CAATSA tasks the US government with compiling a list to identify Russia’s ‘most significant senior foreign political figures and oligarchs’ based on their proximity to the Kremlin – likely as per both documented and alleged ties – as well as their net worth. The report (referred to by some in Washington as “The Kremlin Report”) which is to be submitted by February 2018, will detail information that Russia’s rich and powerful generally prefer to shield from the public eye, including their links to President PUTIN and details concerning their fortune and sources of wealth. A similar list will also identify ‘parastatal’ entities and their ultimate beneficial owners.


Policy analysts have suggested that several criteria be put in place to determine who is named:


1. ‘Those responsible for aggressive, corrupt or criminal operations within or  outside of Russia’
2. ‘Putin’s close circle of allies from St. Petersburg, with whom he has done business since the early 1990s'

3. ’Golden children’ of the elite who may be linked to their parents’ wealth'

4. ‘Personal friends of Putin who, to shield the president from scrutiny, hold considerable wealth for him’

5. ‘So-called oligarchs: big businessmen profiting greatly from direct           business with the Kremlin’

6. Allegedly ‘corrupt state enterprise managers who owe their positions to their close             personal relations with Putin and utilize their positions for gross larceny and;


7.     ‘The relevant companies owned by these people.’



Read the full Newsletter HERE

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