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January 23, 2019

Steve Mnuchin

Secretary

U.S. Department of the Treasury
1500 Avenue, NW
Washington, DC. 20220

Dear Secretary Mnuchin:

I am writing regarding serious concerns I have with a transaction that took place between
yourself and Leonid Blavatnik, a Ukrainian-born oligarch with close ties to U.S. sanctioned
Russian billionaires Oleg Deripaska and Viktor Vekselberg. This transaction is especially
alarming given a New York Times report that these individuals appear to have bene?ted from
the sanctions relief package you proposed in December as Treasury Secretary. The fact that you
did not recuse yourself from deliberations surrounding the proposed termination of sanctions on
RUSAL and En+ is deeply troubling and a con?ict of interest.

It has been reported that you sold an interest in the entertainment company RatPac-Dune to
Blavatnik. Blavatnik is a former board member of RUSAL, which was the intended bene?ciary
of recently proposed sanctions relief. Blavatnik and Vekselberg are partners in SUAL. SUAL is a
major shareholder of RUSAL and its stake will be increased as a direct result of the sanctions
relief package. Blavatnik had a clear ?nancial interest in the outcome of the Treasury action.
Additionally, one of Blavatnik?s companies, Access Industries, contributed $1 million to the
Trump Inauguration.

There is no question that you did in fact sell an interest in RatPac-Dune, per your ?nancial
disclosure for the period in question that reports the RatPac?Dune transaction. In it, you disclosed
a capital gain of more than $5 million to you personally and a capital gain of more than $5
million to a trust for your children. The Hollywood Reporter listed the sale price at $25 million.

Given your business relationships with these individuals and your involvement in twice
delaying sanctions, weakening the penalties, and eventually proposing relief from sanctions there
is clearly a con?ict of interest. Therefore, no action should be taken on Treasury?s sanctions
proposals regarding RUSAL and En+ until Congress has fully evaluated your answers to the
following questions:

0 Regarding previously disclosed transactions involving you and your dependents selling
your interest in Rat-Pac:

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 Which individuals and entities purchased your shares in Rat-Pac and on what
dates?
0 What are the names of any LLCs involved in these transactions, their locations,
and bene?cial owners?
0 How many shares did they purchase?
0 What was the value of each of those transactions?
0 Did the purchaser(s) have any af?liation with U.S.-sanctioned individuals or
entities?
0 Did you obtain ethics advise before engaging in these transactions?
. If yes, what advice did you receive?
I If no, why not?
0 Did you obtain any ethics advice before engaging in or in?uencing deliberations about
amending sanctions applied to companies af?liated with Deripaska?
If yes, what advice did you receive?
0 If no, why not?
0 Have you ever sought an opinion from Treasury?s ethics of?ce or the Of?ce of
Government Ethics on your involvement in sanctions issues?
0 If yes, what advice did you receive?
0 If no, why not?
I Were individuals involved in implementing or amending sanctions on Deripaska aware of
your previous ?nancial relationships with shareholders in Deripaska?s companies?
0 Did James Packer sell shares in Rat-Pac in 2017?
If so, how many shares did he sell and what price did he receive?
0 Do you or did you hold any direct or indirect ?nancial interest in entities subject to US.
sanctions, or those that have been considered sanctions candidates by Treasury of?cials?
- Have you ever in?uenced deliberations on sanctions applications when they involved an
entity in which you had a ?nancial interest or with which you had a relationship?
0 Has Blavatnik, his agent, or any other sanctioned individual sought to appeal to you
directly about sanctions issues?

I look forward to your response to this letter within two weeks of receipt. Please contact
Mitchel Hochb'erg on my staff at or 202?225?3531 with any
questions.

  

 

  
 

Jackie Speier'
Member of Congress