The Kremlin has expanded its secret “black list” of Americans banned from Russia to include Obama campaign fundraisers tied to the LGBT community and senior Congressmen, diplomatic sources tell The Daily Beast. Moscow’s list, these sources say, was expanded in retaliation to the Obama administration’s attack on the assets of key business associates of Vladimir Putin in March.

The Russian government has been working for months to expand the list in response to the three rounds of sanctions against Russian officials, businessmen, and institutions. But unlike the United States, which made all three rounds of sanctions public, the Russian government only publicly revealed one list of sanctioned Americans, which included top Senators and White House officials. The contents of the subsequent additions to the Russian list, however, remain officially undisclosed.

In late March, the Russian Foreign Ministry said publicly that it had responded to the second round of U.S. sanctions by expanding its black list. But the Kremlin said it would not reveal the names publicly.

“Of course, such actions cannot remain unanswered. Russia responded by undertaking similar measures,” the foreign ministry said in a statement that was all-but-ignored in the West.

Russian officials sanctions scoffed at the first U.S. sanctions list, which included mostly politicians. Then the Kremlin crafted a proportional response, sanctioning Americans equivalent to the Russians punished by the U.S. For example, Senate Majority Leader Harry Reid was sanctioned because the U.S. sanctioned Valentina Matvienko, the head of the upper chamber of the Russian Duma.

But the second American list was more personal, going after big businessmen in Russia who were very close to Putin—his moneymen and his cronies. Putin said in late April that he was baffled that the Americans were targeting the Russian oligarchs.

“As for the sanctions, I consider the first package of sanctions an unlawful and hostile act against Russia, and a step that will definitely damage Russia-U.S. and Russia-EU relations. But as for the second package of sanctions, it is not even clear exactly what they are all about, because they have no cause and effect link to what is happening now in Ukraine and in Russia,” he said.

So when the Kremlin responded, the Russians had to get a little creative. Many top American businessmen are not necessarily close to President Obama personally, so Moscow chose to sanction top Obama campaign bundlers as the closest means of direct retaliation.

Diplomatic sources confirmed to The Daily Beast that the expanded and still-secret Russian sanctions list includes five top Obama campaign bundlers as well as about a dozen top Senators and Congressmen who were not included in the first list. The names of the specific bundlers remains a secret, but a focus was put on those with ties to the gay and lesbian community; it’s a reflection of the ongoing fight between the Kremlin and the White House over Russia’s laws punishing the promotion of LGBT “propaganda.”

Because the Russian list is secret, the only way a bundler or lawmaker can determine if he or she is on the sanctions list is to apply for a visa to visit Russia. If the visa is rejected without explanation, the applicant is on the list. Early last year, well before the Ukraine crisis, Rep. Chris Smith discovered he was on Russia’s black list when he applied for a visa. Smith has been a harsh critic of Russia’s record on human rights.

The U.S. released a third list of Russian officials, businessmen, and institutions subject to sanctions last week and more U.S. sanctions could be on the way. Russian media revealed a leaked secret State Department cable dated April 21 asking U.S. embassies in Europe for any information “including compromising materials” about European businesses or officials that have deep ties to Russia.

Putin warned April 29 that he was preparing a new, third round of retaliatory sanctions against U.S. and European businessmen connected to Russia.

“Let me say again that there is nothing good in these sanctions—they will be damaging. The Russian Federation Government has already proposed some countermeasures,” Putin said. “I do not see a need for us to take countermeasures. But if this kind of situation continues, of course we will have to start looking at who is doing what in Russia in different sectors of our economy, including the energy sector.”

Putin didn’t mention that his black list had already grown.