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UK Releases Guidance on How It Collects Russian Sanctions Data

The U.K. released guidance on how it collects data on its Russia sanctions regime. The Foreign, Commonwealth & Development Office published sections on the sanctions' legislation, data collected "post invasion," individual designations, estimates of oligarchs' net worths, oligarchs' family members and sanctions on entities.

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The FCDO said an "oligarch" is a “Russian national who is both ultra-high-net-worth and connected to the Putin regime." The guidance said the U.K. uses the Forbes billionaire list for oligarch global net worth estimates and the total global net worth of the sanctioned oligarchs is over $140 billion. Using open source research, the U.K. estimates the number of subsidiaries covered by U.K. sanctions to be around 420, in addition to 1,083 individuals and 106 entities.