Important Notice — Historical and Current Status
This publication contains a retrospective sanctions and compliance assessment based principally on information available as of 15 September 2025.
Sanctions designations and restrictions may subsequently change. Accordingly, this historical profile must not be interpreted as confirmation of the subject’s current sanctions status in any jurisdiction.
Where subsequent developments are material, they are identified separately below.
Before relying on this profile for a transaction, compliance decision, regulatory filing or legal assessment, the relevant current official sanctions register should be consulted.
The International Sanctions Delisting Commission (ISDC) is an independent non-governmental review institution. It does not impose, administer, maintain or remove government sanctions. Its publications constitute independent research and analysis and are not governmental, judicial or regulatory decisions. (ISDC)
01 — Executive Profile
Anatoly Borisovich Chubais is a Russian economist, former senior government official and former executive of major Russian state-linked enterprises.
He became one of the most prominent figures in Russia’s post-Soviet economic transformation and played a central role in the development and implementation of the country’s economic reform and privatisation programme.
His subsequent career included senior positions within the Russian government and presidential administration, the chairmanship of RAO UES of Russia, and leadership of RUSNANO.
In 2020, Chubais was appointed Special Presidential Representative for Relations with International Organisations.
He left Russia in 2022 following the beginning of Russia’s full-scale invasion of Ukraine.
His professional history makes him relevant to political-exposure, sanctions and geopolitical due-diligence analysis.
02 — Political and Government Career
Chubais became one of the principal architects of Russia’s economic reforms during the transition from the Soviet system to a market economy.
During the 1990s, he served in senior government positions and was closely associated with the administration of President Boris Yeltsin.
He was particularly prominent in the development and implementation of Russia’s privatisation programme.
His subsequent career continued to involve senior positions within Russian state institutions and state-controlled enterprises.
These positions are relevant to politically exposed person (PEP) analysis.
They do not, by themselves, constitute evidence of unlawful conduct, corruption or other wrongdoing.
03 — RAO UES
From 1998 to 2008, Chubais served as Chairman of the Management Board of RAO UES of Russia, at the time one of the country’s largest electricity utilities.
During his tenure, RAO UES underwent a major restructuring intended to separate generation, transmission and distribution activities and introduce greater competition into the electricity sector.
The restructuring represented one of the largest transformations of Russia’s energy industry during the post-Soviet period.
Assessments of the restructuring vary significantly depending on political and economic perspective.
This review does not treat those differing assessments as findings of unlawful conduct.
04 — RUSNANO
In 2008, Chubais became Chairman of the Executive Board of RUSNANO, a Russian state-backed institution established to promote investment and development in nanotechnology and high-technology industries.
The position placed him at the intersection of Russian state policy, strategic investment and international technology cooperation.
He remained associated with RUSNANO until 2020.
Public commentary concerning RUSNANO has included differing assessments of its investment performance and economic effectiveness.
Such criticism should be distinguished from formal findings by a competent legal or regulatory authority.
05 — Relationship with the Russian State
Chubais originated from the liberal economic reform movement of the late Soviet and early post-Soviet period.
Nevertheless, his subsequent professional career involved extensive cooperation with Russian state institutions.
He occupied senior government positions, led strategically important state-linked enterprises and maintained professional access to senior Russian political and economic institutions.
In 2020, he was appointed Special Presidential Representative for Relations with International Organisations.
This position connected him with the Russian presidential administration and international governmental and institutional networks.
The existence of these professional relationships is a matter of public record and does not by itself establish improper conduct.
06 — Departure from Russia
Chubais left Russia in 2022 following the beginning of Russia’s full-scale invasion of Ukraine.
His departure attracted substantial international attention because of his previous senior positions within the Russian government and state-controlled corporate sector.
His subsequent international profile remains relevant to sanctions, geopolitical and political-risk analysis.
07 — Sanctions Position as of 15 September 2025
As of the profile date of 15 September 2025, the Ukrainian State Sanctions Register identified the following jurisdictions in connection with Chubais:
- United States
- Canada
- Switzerland
- European Union
- United Kingdom
- Australia
- New Zealand
- Japan
The Ukrainian sanctions authority’s profile identifies these jurisdictions in connection with Chubais. (War & Sanctions)
For purposes of this historical profile, these jurisdictions are therefore recorded as sanctions jurisdictions identified as of 15 September 2025.
This should not be interpreted as confirmation that all of these restrictions remain in force today.
Current sanctions status must be established from the relevant jurisdiction’s official register.
08 — European Union
As of 15 September 2025, the EU maintained restrictive measures concerning persons designated under its Russia-related sanctions framework.
The EU sanctions framework includes measures such as:
- asset freezes;
- prohibitions on making funds or economic resources available to designated persons; and
- travel restrictions where applicable.
The relevant EU measures and their duration are determined by the applicable Council decisions and regulations.
The existence, continuation or expiry of a designation should therefore be verified against the current EU legal instruments before any transaction or compliance decision.
The EU continues to maintain and update its Russia-related sanctions framework. (Finance EU)
09 — United States
The Ukrainian State Sanctions Register identifies the United States among the jurisdictions associated with sanctions concerning Chubais. (War & Sanctions)
US sanctions are administered principally by the US Department of the Treasury’s Office of Foreign Assets Control (OFAC).
Because US sanctions status is jurisdiction-specific and may change independently of other sanctions regimes, any current assessment should be made directly against the applicable OFAC records.
Accordingly, this historical profile does not purport to establish Chubais’s current US sanctions status.
10 — United Kingdom
The Ukrainian State Sanctions Register identifies the United Kingdom among the jurisdictions associated with sanctions concerning Chubais. (War & Sanctions)
The UK maintains its own Russia sanctions regime and its own designation records.
Since 28 January 2026, the UK Sanctions List has been the official source for UK sanctions designations. The UK government continues to update the list and Russia sanctions regime. (GOV.UK)
Accordingly, the historical reference in this profile should not be treated as a statement of Chubais’s current UK designation without checking the current UK Sanctions List.
11 — Switzerland
The Ukrainian State Sanctions Register identifies Switzerland among the jurisdictions associated with sanctions concerning Chubais. (War & Sanctions)
Swiss sanctions are administered under Switzerland’s own legal framework.
Any current compliance assessment should therefore be based on the current Swiss sanctions register and applicable Swiss legal instruments.
12 — Canada
Historical designation
Canada designated Anatoly Borisovich Chubais on 13 June 2025 under the Special Economic Measures (Russia) Regulations.
As of the profile date of 15 September 2025, he was therefore subject to Canadian sanctions.
Subsequent development — delisting
A material subsequent development occurred in August 2026.
The Canadian government formally removed Anatoly Borisovich Chubais from Schedule 1 of the Special Economic Measures (Russia) Regulations.
The Canadian Gazette confirms both:
- the original designation on 13 June 2025; and
- the subsequent removal from the sanctions schedule.
The Canadian government expressly states that, following the amendment, the restrictions and prohibitions under the Russia Regulations no longer applied to Chubais. (gazette.gc.ca)
Current Canadian status: Delisted.
This subsequent development is material and should not be omitted from any current presentation of the case.
13 — Australia, New Zealand and Japan
As of the profile date, the Ukrainian State Sanctions Register identified:
- Australia;
- New Zealand; and
- Japan
among the jurisdictions associated with sanctions concerning Chubais. (War & Sanctions)
The sanctions position in each jurisdiction is legally independent.
Accordingly, the historical identification of a jurisdiction in this profile should not be treated as proof that restrictions remain in force today.
Current official registers should be consulted before any transaction or compliance decision.
14 — Sanctions Status Summary
Historical position — 15 September 2025
| Jurisdiction | Historical status |
|---|---|
| United States | Identified as sanctions jurisdiction |
| European Union | Identified as sanctions jurisdiction |
| United Kingdom | Identified as sanctions jurisdiction |
| Switzerland | Identified as sanctions jurisdiction |
| Canada | Designated on 13 June 2025 |
| Australia | Identified as sanctions jurisdiction |
| New Zealand | Identified as sanctions jurisdiction |
| Japan | Identified as sanctions jurisdiction |
These historical jurisdictional references are based principally on the Ukrainian State Sanctions Register, with Canada’s original designation independently confirmed by the Canadian government. (gazette.gc.ca)
Confirmed subsequent development
Canada — Delisted in August 2026. (gazette.gc.ca)
For all other jurisdictions, current status should be established directly from the applicable official register.
15 — International Network
Throughout his career, Chubais developed professional relationships with:
- foreign governments;
- international financial institutions;
- multinational corporations;
- technology companies;
- investment institutions;
- international organisations; and
- senior political and economic representatives.
His previous positions gave him access to Russian state institutions and international economic and political networks.
This background is relevant to sanctions and political-risk due diligence.
It does not, by itself, establish improper relationships or unlawful conduct.
16 — Reputation and Controversies
Chubais remains one of the most consequential and controversial figures of Russia’s post-Soviet economic transformation.
Supporters of the reforms of the 1990s have associated him with Russia’s transition toward a market economy and the development of modern economic institutions.
Critics have associated his name with the social and economic consequences of rapid privatisation and the concentration of economic assets during the post-Soviet transition.
His management of RAO UES and RUSNANO has also generated differing assessments concerning the effectiveness and consequences of large-scale state economic reforms.
These political and economic assessments must be distinguished from formal legal grounds underlying sanctions imposed by individual jurisdictions.
This review does not characterise political criticism as evidence of criminal or unlawful conduct.
17 — Analytical Assessment
Chubais represents a distinctive category of Russian politically exposed person.
His career combines:
- senior government service;
- participation in Russia’s post-Soviet economic reforms;
- leadership of strategically important state-linked enterprises;
- involvement in major economic restructuring;
- a senior role within the Russian presidential administration;
- extensive international professional contacts; and
- historical exposure to multiple sanctions jurisdictions.
The principal compliance relevance of the case lies in the combination of political exposure, senior state-sector positions and international activity.
Sanctions should always be assessed jurisdiction by jurisdiction, taking into account:
- the relevant legal instrument;
- designation date;
- stated grounds;
- applicable restrictions;
- subsequent amendments;
- revocations or delistings; and
- current official records.
18 — No Finding of Wrongdoing
Nothing in this review should be interpreted as a finding that Anatoly Chubais:
- committed a criminal offence;
- engaged in corruption;
- committed fraud;
- unlawfully acquired assets;
- evaded sanctions;
- concealed beneficial ownership;
- acted as a nominee for another person; or
- engaged in any other unlawful conduct,
unless such conduct is established by a competent authority or supported by specific documentary evidence.
Political controversy, government service, corporate leadership or sanctions designation should not independently be treated as proof of criminality.
19 — Current Compliance Questions
For any current transaction or due-diligence exercise involving Chubais, the following questions should be addressed:
Current sanctions status
Is the person currently designated in the relevant jurisdiction?
Historical designation
What was the original legal basis and stated reason for designation?
Subsequent changes
Has the designation been amended, revoked, suspended or otherwise changed?
Assets
Are any assets currently subject to restrictions?
Financial institutions
Would the transaction involve a regulated institution subject to sanctions obligations?
Jurisdiction
Which sanctions regime governs the proposed transaction?
PEP exposure
Does the transaction require enhanced due diligence because of the subject’s political history?
Source of wealth and funds
Where legally and commercially appropriate, has the relevant source of wealth/funds been established?
20 — Conclusion
As of 15 September 2025, Anatoly Chubais was a former senior Russian government and state-enterprise figure identified by the Ukrainian State Sanctions Register as being subject to sanctions-related measures across multiple jurisdictions. (War & Sanctions)
His professional history spans Russia’s post-Soviet economic reforms, privatisation programme, restructuring of the electricity sector, state-backed technology investment and senior interaction with international organisations.
The combination of his political history, senior state appointments, strategic-sector involvement and international professional network makes him a relevant subject for sanctions, PEP and geopolitical due-diligence analysis.
A significant subsequent development is that Canada removed Chubais from its sanctions list in August 2026. The Canadian government expressly confirmed that the restrictions under the relevant Russia sanctions regulations no longer applied to him. (gazette.gc.ca)
Accordingly, this case should be understood as a historical sanctions review with a documented subsequent Canadian delisting, rather than as a statement that Chubais remains sanctioned in every jurisdiction listed in the historical profile.
Any current legal or compliance assessment should be based on the current official sanctions register of the relevant jurisdiction.
Methodology and Editorial Standard
This review distinguishes between:
- primary government and regulatory records;
- sanctions registers;
- reputable public reporting;
- historical corporate and political information;
- sanctions authorities’ stated reasons;
- independent compliance analysis; and
- matters requiring further documentary verification.
ISDC does not impose, maintain, suspend or remove government sanctions.
Acceptance or review of a case does not imply support for sanctions or delisting and does not constitute a finding of wrongdoing.
The purpose of this publication is to provide an independent, evidence-based sanctions and compliance assessment.
Current sanctions status must always be verified against the applicable official register before reliance for a transaction, legal proceeding, regulatory filing or compliance decision.