The Yermak-McFaul International Working Group on Sanctions against Russia presented a Roadmap for individual sanctions. The document defines the objectives of individual sanctions, the principles of their application, comprehensively names all categories of persons against whom personal sanctions should be imposed, and proposes a strategy to increase sanctions pressure.
The purpose of individual sanctions is to increase pressure on the ruling elites of the regime, and thus help end the war against Ukraine. The Group proposes to impose sanctions on those categories of persons for whom it will be the fastest and most effective. That is, it is proposed to choose those categories of persons, personal sanctions of the democratic world against which will be the most painful.
The following types of persons subject to sanctions are offered in order of priority: oligarchs, senior government officials, key corporate executives, including foreigners, Russian propagandists, political party leaders, family members, and proxies. The Group also proposes to consider introducing individual sanctions against all Russian athletes. The appendix to the document explains in detail who belongs to the appropriate category.
The number of potential candidates for sanctions will be at least 12,000 individuals and 3,000 legal entities. The immediate priority is given to the 100 wealthiest people on Russia's Forbes list.
According to the white paper, the sanctions coalition should focus on those who have been able to avoid sanctions in most or all jurisdictions. Examples are Vladimir Potanin, owner of Norilsk Nickel and other large assets, Andrey Bokarev, co-owner of Transmashholding and other significant assets; and Iskander Makhmudov, co-owner of Transoil, Transmashholding and other significant assets.
The key sanctions mechanisms should be the freezing of assets, the ban on entry into the countries of the sanctions coalition, and the termination of powers in Western companies. It is crucial to involve as many countries as possible in a coalition of sanctions. If a person is subject to sanctions in one jurisdiction, all other jurisdictions should be the case. The role of the Ukrainian government in making any decisions on sanctions is emphasized.
Also, according to the Group, any attempts by senior government officials, heads of corporations and board members, propagandists, and members of political parties to transfer property to their family members or proxies should be carefully monitored and prevented. Any assistance in transmitting or receiving such assets should be grounds for imposing sanctions.
This roadmap and the previous papers of the Yermak-McFaul Group - Action Plan for Strengthening Sanctions and the Roadmap for Energy Sanctions have been provided to all key decision-makers. It is vital to continue to increase sanctions pressure on Russia.