The U.S. Department of the Treasury’s Office of Foreign Assets Control recently applied sanctions against individuals who had served on the supervisory board of the Alfa Group Consortium, one of the largest financial and investment conglomerates in Russia. Deputy Secretary of the Treasury Wally Adeyemo declared, “Wealthy Russian elites should disabuse themselves of the notion that they can operate business as usual while the Kremlin wages war against the Ukrainian people. Our international coalition will continue to hold accountable those enabling the unjustified and unprovoked invasion of Ukraine.” Adeyemo’s big words, however, represent a goal, not the current reality. Althou
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