However, being on the list will increase the risk of being sanctioned in the future – under so-called secondary sanctions.For instance, Section 232 of the relevant bill, with respect to Russia´s energy export pipelines reads: “The President, in coordination with allies of the United States, may impose five or more of the sanctions […] to a person if the President determines that the person knowingly, on or after the date of the enactment of this Act, makes an investment described in subsection (b) or sells, leases, or provides to the Russian Federation, for the construction of Russian energy export pipelines, goods, services, technology, information, or support”.To defend his elites, the Russian president also announced a capital amnesty programme to incentivize wealthy Russians to repatriate their overseas assets.It is estimated that 0 billion in financial assets are held in offshore tax heavens, which constitutes 60% of Russia´s overall wealth.
Because previous sanctions were imposed by Obama by an executive order, a new president could lift them altogether by another executive order.
But there are a number of unknowns surrounding the imposition of these extra-territorial (secondary) sanctions: firstly, it is discretionary, depending on whether the President considers it to be necessary.
Second, no mechanism is specified of how “in coordination with allies” will be achieved.
According to the “Countering America´s Adversaries Through Sanctions Act” (CAATSA), the report required to be produced by 29 January should list all the senior foreign political figures and oligarchs, who are close to the Russian government, together with their estimated net worth.
The report will include an assessment of their proximity to the Russian political elites and identify any indication of corruption in their business activities inside and outside of Russia.