The list, submitted to Congress under the Countering America's Adversaries Through Sanctions Act of 2017, was highly anticipated in Russia. Some wealthy business executives were reported to have hired lobbyists in Washington to stay off the list or to have applied for foreign passports to sidestep possible sanctions.
In the end, the list appeared to have been copied and pasted from two sources widely available to the public: the Forbes rankings of the wealthiest Russians and the Kremlin's directory of officials, which is available on its English-language website. The 96 business executives listed by the Treasury Department are the same as those indicated to have a net worth of more than $1 billion, according to Forbes.
"One does not have to be very smart to make this list," Mikhail Fedotov, the head of the Kremlin Human Rights Council, said in remarks to journalists. He was also on the list. "It would suffice to visit the Kremlin website and take a look at the names of the administration heads, presidential advisers, presidential aides, et cetera. This is not a great piece of work."
There is also a classified section of the Treasury Department report that was not released to the public.
In emailed remarks, a Treasury Department spokesman said the unclassified portion of the report "was derived from open sources, including Russian sources, such as kremlin.ru, Forbes, and others." Since there is no definition of an oligarch, the spokesman said, $1 billion was chosen as "a reasonable number, which is the criteria contained in the U.S. Forbes list of Russian individuals with a net worth of at least $1 billion."
He said that the Treasury Department would not comment on the classified portion of the list, which draws attention "to certain other individuals who we deemed to be significant, but about which classified information was necessary to explain their role and activities."
Adam Smith, a former Treasury official who worked on sanctions against Russia, said what was released to the public was no more than a "mechanical" fulfillment of a legal requirement. Not everyone on the oligarchs list still lives in Russia. And not everyone is close to Putin.
"There seems to be nothing subjective or interpretive about either the senior political figures or the oligarchs list," he said of the people named publicly. "If you are in the Putin administration, you are on the list; if you are worth $1 billion or more, you are on the list."
Those who are will not necessarily have sanctions imposed on them, though some already are under previous sanctions.
Many Democrats were angered that the named oligarchs were not sanctioned. Nor did the administration impose sanctions under another part of the legislation, which aimed to punish Russia for interfering in the 2016 presidential election. "There should be outrage in every corner of this country," tweeted Sen. Claire McCaskill (D-Mo.), the top Democrat on the Senate Homeland Security Committee.
Even Republicans were concerned. "I'd like to know why they're not doing more," said Sen. Lindsey O. Graham (R-S.C.). "There may be a good reason but I don't want to send anything that could be a signal of weakness."
The list is not without bite, however. Erich Ferrari, a Washington lawyer who specializes in sanctions, said that those named may face delays in some financial transactions as international banks subject them to more scrutiny. He said some British banks already have included them among "politically exposed" clients, and the list may be fodder for legal challenges.
But many minimized the significance of the public list, which appears to have been assembled in haste for release 11 minutes before the midnight deadline.
Daniel Fried, who coordinated sanctions policy at the State Department in the Obama administration, likened it to a "cut and paste job" that duplicated an error in the Forbes list of rich Russians, suggesting that its compilers did not bother to check the magazine's work.
"The public list is so broad and inclusive and so undiscriminatory that it undercut the purpose" of the law, he said, "which was not to go after all rich Russians or all corrupt rich Russians, but to go after the Putin power structure. . . . I don't know why the administration thought it was to its advantage to go another route and simply slap something together."
Fried said that professionals within the administration were preparing a more-carefully curated list of Russians who are not only rich but close to Putin. Those names may be on the classified list.
As is, he added, "this was a missed opportunity by the administration," but Putin and his inner circle have no cause to chortle. "If Russia is wise, it will understand the United States has little tolerance left for Russian aggression, and will back off," Fried said.
Many Russians made light of the list. Even Putin joked that he felt "slighted" by being left off.
"The importance of this list is null," said Russian Prime Minister Dmitry Medvedev, who then added a joke: "I believe in this case not being included on this list provides grounds for resignation."
Also on Tuesday, Russian state media reported that Sergei Naryshkin, the head of Russia's foreign spy service, who has had sanctions imposed on him under U.S. law but can visit the country on official business, had met for discussions in the United States with American officials regarding the war on terrorism.
Morello reported from Washington.