Congress hit a nerve in Moscow last summer when it passed (and President Donald Trump signed) H.R. 3364, the “Countering America’s Adversaries Through Sanctions Act.” Beyond the law’s many sanctions, its Section 241 requires the administration to submit to Congress a detailed report identifying “the most significant senior foreign political figures and oligarchs in the Russian Federation, as determined by their closeness to the Russian regime and their net worth” within 180 days.

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