08/23/2024 | News release | Distributed by Public on 08/23/2024 08:32
One day ahead of Ukrainian Independence Day, Treasury continues implementation of G7 sanctions commitments in support of Ukraine
WASHINGTON - Building on the sanctions already imposed on Russia in response to its continued war of aggression against Ukraine, today the U.S. Department of the Treasury and the Department of State targeted nearly 400 individuals and entities both in Russia and outside its borders-including in Asia, Europe, and the Middle East-whose products and services enable Russia to sustain its war effort and evade sanctions. The United States government will continue to support Ukraine as it defends its independence and hold Russia accountable for its aggression.
"Russia has turned its economy into a tool in service of the Kremlin's military industrial complex. Treasury's actions today continue to implement the commitments made by President Biden and his G7 counterparts to disrupt Russia's military-industrial base supply chains and payment channels," said Deputy Secretary of the Treasury Wally Adeyemo. "Companies, financial institutions, and governments around the world need to ensure they are not supporting Russia's military-industrial supply chains."
Treasury is targeting numerous transnational networks, including those involved in procuring ammunition and military materiel for Russia, facilitating sanctions evasion for Russian oligarchs through offshore trust and corporate formation services, evading sanctions imposed on Russia's cyber actors, laundering gold for a sanctioned Russian gold company, and supporting Russia's military-industrial base by procuring sensitive and critical items such as advanced machine tools and electronic components. Today's sanctions further limit Russia's future revenue from metals and mining. Treasury is also targeting Russian financial technology companies that provide necessary software and IT solutions for Russia's financial sector.
Treasury is aware of Russian efforts to facilitate sanctions evasion by opening new overseas branches and subsidiaries of Russian financial institutions. Foreign regulators and financial institutions should be cautious about any dealings with overseas branches or subsidiaries of Russian financial institutions, including efforts to open new branches or subsidiaries of Russian financial institutions that are not themselves sanctioned.Treasury has a range of tools available to respond to the establishment of new evasion channels.
The State Department is targeting entities and individuals involved in Russia's future energy, metals, and mining production and exports; sanctions evasion; Russia's military-industrial base, including armed unmanned aerial vehicle (UAV) production, Belarusian support for Russia's war effort, and air logistics entities; additional subsidiaries of State Atomic Energy Corporation Rosatom; and malign actors involved in the attempted, forcible "re-education" of Ukraine's children.
SANCTIONS EVASION, CIRCUMVENTION, AND BACKFILL
Consistent with commitments made by President Biden and G7 leaders, Treasury continues to target transnational networks that supply Russia with military materiel and sensitive dual-use goods like those included in the multilateral Common High Priority List, jointly developed by the United States, European Union, Japan, and the United Kingdom. Treasury is also targeting multiple networks that facilitate or enable illicit financial schemes and sanctions evasion on behalf of Russian revenue generators and oligarchs. Many of today's designations were enabled or informed by extensive coordination with Treasury's Financial Crimes Enforcement Network (FinCEN). Today's action targets almost a dozen distinct networks, designating more than 100 individuals and entities across 16 jurisdictions, including the People's Republic of China, Switzerland, Türkiye, and the United Arab Emirates.
For more information on these targets, please see Annex 1.
RUSSIA'S TECHNOLOGICAL BASE
Today, Treasury is targeting more than 60 Russia-based technology and defense companies that are critical for the sustainment and development of Russia's defense industry, including entities involved in weapons development and modernization, automation and robotics, development and acquisition of dual-use electronics, digital surveillance, Internet of Things, and artificial intelligence. These sanctions target Russia's defense industry while protecting the access by Russian citizens to crucial telecommunications and other digital technology.
For more information on these targets, please see Annex 2.
LIMITING RUSSIA'S STRATEGIC METALS AND MINING SECTOR
Guided by commitments made by President Biden and G7 leaders to reduce Russia's revenues from metals, today Treasury is targeting entities involved in Russia's metals and mining sector, including steel, iron, and coal mining firms and auxiliary firms that provide specialized services to Russian metals and mining companies.
For more information on these targets, please see Annex 3.
RUSSIAN FINANCIAL TECHNOLOGY
Today, OFAC is targeting Russian financial technology companies as a part of implementing G7 commitments to curtail Russia's use of and access to the international financial system to further its war against Ukraine.
Atol is a Russian technology developer involved in services related to payments.
Centre of Financial Technologies Group (CFT)is one of the largest software companies in the Russian market. CFT provides an array of software products for banking and payment solutions for the Russian financial market.
Diasoft Ltd (Diasoft) is one of Russia's largest developers and suppliers of information technology (IT) solutions for the financial sector.
Atol, CFT, and Diasoft were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy.
ANNEX 1: SANCTIONS EVASION, CIRCUMVENTION, AND BACKFILL
Ammunition Procurement Network
Italian national Giulio Sfoglietti (Sfoglietti) has been involved in a procurement network involving a Türkiye facilitator to purchase more than $150 million worth of military equipment, ammunition, and ordnance for the Russian military from potential suppliers in Africa, Asia, the Caucasus, Central Asia, and Iran. Türkiye national Hayri Tahirbeyoglu (Tahirbeyoglu) is the Chairman of the Board of Directors of Türkiye-based ammunition, weapons, and military materiel company Taha Savunma Sanayi Ve Ticaret Anonim Sirketi (Taha Savunma) and has worked with Sfoglietti on the procurement of ammunition and weapons for likely Russian end-use. Sfoglietti has also worked to procure microelectronics and chips for Russia-based end-users.
Sfoglietti associate Russian national Marat Khanbalevich Gabitov (Gabitov) has worked with an employee of U.S.-designated Russian defense conglomerate State Corporation Rostec to procure microelectronics related to radio frequency (RF) equipment. Gabitov has also worked to procure microelectronics, unmanned aerial vehicles (UAVs), and other machinery and equipment for Russia-based end-users.
Sfoglietti was designated pursuant to E.O. 14024 for operating or having operated in the defense and related materiel and technology sectors of the Russian Federation economy. Tahirbeyoglu and Taha Savunma were designated pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector of the Russian Federation economy. Gabitov was designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy.
Promtekh Supply Chain
U.S.-designated Russia-based Aktsionernoe Obshchestvo Promyshlennye Tekhnologii (Promtekh) has used a network of companies located in Türkiye, France, and Hong Kong to send high priority goods to Promtekh's subsidiaries. Russia-based Aspectriym Limited Trade Development (Aspectriym) is a subsidiary of Promtekh and is a defense procurement firm involved in the wholesale of electronic equipment and parts.
France-based Industrial Technologies Group France (ITGF) is a sister firm of U.S.-designated Promtechcomplekt JSC, a subsidiary of Promtekh, and has worked with Aspectriym to procure foreign- and U.S.-made electronic components. Hong Kong-based Interasia Trading Group Limited (Interasia Trading) is the sole owner of ITGF. Russian national Igor Aleksandrovich Reutov (Reutov) is the Executive Director of ITGF. Reutov is also the owner of Estonia-based Free Sky Solutions OU (Free Sky) and the Managing Partner of France-based Aerialia. Aerialia was established in January 2024.
ITGF also created a Türkiye-based firm, Enutek Makina Sanayi ve Ticaret Limited Sirketi (Enutek). Enutek has made hundreds of shipments of technology, including high priority dual-use technology such as electronic integrated circuits and ceramic capacitors, to U.S.-designated Promtekh subsidiaries, including Promtech Ulyanovsk, Dubna Switching Equipment Plant, and Promtech Irkutsk. Enutek was established in December 2022.
Other foreign suppliers to Promtekh subsidiaries include:
Aspectriym, ITGF, Enutek, Interasia Trading, Reutov, Confienza, Grun Group, Yayang Trading, Kira International, Most Development, and New Wally Target were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy. Free Sky and Aerialia were designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Reutov.
Sanctions Evasion Through Switzerland and Liechtenstein Trust and Corporate Services Providers
Swiss national Anton Daniel Wyss (Wyss) is a major enabler of Russian cash flow in Switzerland and Liechtenstein and has used his Liechtenstein-based trust and corporate services provider (TCSP) Audax Consulting Trust Establishment (Audax) to obfuscate Russian beneficial ownership and investments into foreign ventures. Through their co-owned Liechtenstein-based company One Asset Management AG (One Asset), Wyss and his Austrian national associate Alexander Franz Josef Lins (Lins) provide asset management and reallocation services to sanctioned Russian nationals. Lins uses his own TCSP, Liechtenstein-based LMG Lighthouse Trust Reg (LMG), to facilitate sanctions evasion schemes for Russian clients. Audax, One Asset, and LMG are all located at the same address, and both Audax and LMG advertise their services in Russian-language brochures. Austrian national Stefan Anton Wolf (Wolf) is a director of Audax.
Wyss, Audax, LMG, and Lins were designated pursuant to E.O. 14024 for operating or having operated in the trust and corporate formation services sector of the Russian Federation economy. Wolf was designated pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of Audax. One Asset was designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Wyss and Lins.
PRC-based Suppliers to Russia's Military-Industrial Base
The following entities were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy:
Fighter Jet Supply Network
Russia-based Exiton has imported foreign electronic components into Russia and supplies U.S.-designated Russian company Joint Stock Company Experimental Design Bureau named after A.S. Yakovlev, a manufacturer involved in the production of Sukhoi fighter jets. Russia-based Limited Liability Company Eksiton (Eksiton) imports high priority goods, including electronic integrated circuits. Hungary-based Matrix Metal Group Korlatolt Felelossegu Tarsasag Felszamolas Alatt (Matrix Metal) has supplied high priority goods, including electronic integrated circuits, to Eksiton. Additionally, Russia-based military contractor and developer of anti-aircraft systems Aktsionernoe Obshchestvo Displei Komponent (Displei Komponent) has received regular shipments of electronic components from both Matrix Metal and Cyprus-based Noratec Holdings Ltd.
Exiton, Eksiton, Matrix Metal, Displei Komponent, and Noratec Holdings Ltd were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy.
Alexandre Orloff
Swiss-Russian national Alexandre Orloff (Orloff) has been working with a Russian government covert procurement network for years to acquire high-value, foreign-made semiconductor-related equipment and technology for Russian military end-users. Orloff has also been part of a scheme to acquire specialized thermal cameras for a Russian end-user.
Orloff owns and is the director and secretary of an eponymous United Kingdom-based company, Alexandre Orloff Ltd (AO Ltd). AO Ltd, in turn, owns Hong Kong-based Zvigeni Technological Systems Limited (Zvigeni) and Dougong Trading Hong Kong Limited (Dougong) and Canada-based 9105 2829 Quebec Inc. Orloff is also the founder and CEO of UAE-based Digital Marketing Awards FZ LLC (DMA).
PRC-based Shanghai Techinital Materials Co Ltd (Shanghai Techinital), a producer of components for semiconductor manufacturing equipment, has made dozens of shipments to U.S.-designated Joint Stock Company Scan (JSC Scan), including of high priority dual-use technology such as signal generators and oscilloscopes. JSC Scan designs microelectronics and has its own center for designing integrated circuits. Shanghai Techinital has open contracts to provide JSC Scan with technology, despite the latter's designation. In 2023 alone, Zvigeni transmitted more than $1.5 million to Shanghai Techinital.
Orloff and Shanghai Techinital were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy. AO Ltd, Zvigeni, Dougong, 9105 2829 Quebec Inc, and DMA were designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Orloff.
Russian Evasion of Cyber Sanctions
In June 2018, the Department of the Treasury sanctioned a network of entities working at the behest of the Russian Federation and its military and intelligence units to increase Russia's malicious cyber capabilities. Since that time, individuals associated with those entities, including Ilya Medvedovsky (Medvedovsky), Dmitriy Evdokimov (Evdokimov), Yevgeniya Klimina (Klimina), Dmitriy Chastuhin (Chastuhin), Taranjeet Kambo (Kambo), and Gleb Cherbov (Cherbov) have established, developed, and supported a complex network of technology companies to continue their work unimpeded. The front companies set up by these individuals, at times registered in the names of family members, operate primarily in the technology sector of the Russian Federation economy, with efforts being taken by individuals such as Chastuhin and Klimina, to establish a technology presence outside of Russia. Included in these companies is OOO Soft Plyus, a Russia-based firm that sells cyber security software and is formerly known as OOO Hexway, for whom Chastuhin has claimed to be the founder and CEO; Cloudrun LLC, a Russia-based company founded by Evdokimov that develops computer software; Didzhital Komplaens, OOO and Kiber Servis, OOO, both of which offer cyber security services and were founded by an individual believed to be related to Medvedovksy; Didzhital Sekyuriti Servisis, OOO; and Machine Learning Labs S.R.O., founded and owned by Klimina. Medvedovsky, alongside Chastuhin, Cherbov, and Klimina, have been involved in decision making related to the operation of Soft Plyus and other related companies, whereas Kambo and Cherbov have worked together to service customers of Soft Plyus.
Medvedovsky, Klimina, OOO Soft Plyus, Cloudrun LLC, Didzhital Komplaens, OOO, Didzhital Sekyuriti Servisis, OOO, and Kiber Servis, OOO, were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy. Chastuhin was designated pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of OOO Soft Plyus. Evdokimov was designated pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of Cloudrun LLC. Cherbov and Kambo were designated pursuant to E.O. 14024 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, OOO Soft Plyus. Machine Learning Labs S.R.O. was designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Klimina.
Alikhanov Machine Tool Procurement
Italy-based machine tool manufacturer Fagima Fresatrici SPA (Fagima) has worked closely with U.S.-designated Russian procurement agent Dmitrii Vladimirovich Alikhanov (Alikhanov) to facilitate the shipment of Fagima-produced machines through various third-country intermediary companies for Russian defense end-users. Fagima's owner and CEO Massimo Falchini (Falchini) and Fagima marketing executive Fulvio Salvadori (Salvadori) have helped fulfill orders for Alikhanov's network and evade sanctions, including after Alikhanov's designation in June 2024.
Fagima, Falchini, and Salvadori were designated pursuant to E.O. 14024 for operating or having operated in the manufacturing sector of the Russian Federation economy.
Illicit Russian Gold Trade
UAE-based, UK-sanctionedPaloma Precious DMCC (Paloma Precious) is a precious metals trading firm that has helped move Russian gold abroad. Paloma Precious and U.S.-designated Taube Precious HK Limited played a key role in numerous illicit Russian gold trading and laundering schemes, including with U.S.-designated Andrey Dmitriyevich Sudakov (Sudakov). Sudakov, an employee of U.S.-designated Russian gold producer Public Joint Stock Company Polyus, and his Hong Kong-based associate Mu Xiaolu (Mu), engaged in a complex, multi-layered laundering scheme whereby payments from the sale of Russian-origin gold were converted into fiat currency and cryptocurrencies through numerous UAE and Hong Kong-based front companies.
UAE-based Russian national Vladislav Faridovich Guzey (Guzey) has worked closely with Sudakov and Mu to launder proceeds of Russian-origin gold through UAE- and Hong-Kong based entities. As part of their effort to move Russia-origin gold, Sudakov and Mu utilized UAE-based front companies Shams Gold Trading FZE (Shams) and Swiss Luxury FZE (Swiss Luxury), and Hong Kong-based front companies Universal Gold Hong Kong Limited (Universal Gold) and Bright Universe International Limited (Bright Universe).
UAE-based Trio Jewells LLC (Trio) has made dozens of shipments of precious metal ingots to and from a Russia-based precious metals producer and processor.
Paloma Precious, Guzey, Shams, Swiss Luxury, Universal Gold, Bright Universe, and Trio were designated pursuant to E.O. 14024 for operating or having operated in the metals and mining sector of the Russian Federation economy.
Petrov Covert Procurement
Türkiye-based Whitestone Bilism Tic Ve Sanayi Ltd Sti (Whitestone) is owned by U.S.-designatedEvgenii Stanislavich Petrov (Petrov) and has been used by Petrov to process payments for Petrov's procurement activity for Russian end-users linked to Russia's intelligence services. Petrov has acted as a covert procurement intermediary and has worked to obtain export-controlled foreign-made products on behalf of Russian-end-users. Whitestone was established in October 2023. Treasury also previously designated Türkiye-based MSO Lojistik Tic Ve Sanayi Ltd Sti for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Petrov.
Whitestone was designated for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Petrov, a person whose property and interest in property are blocked pursuant to E.O. 14024.
Dalkos
Russia-based machinery and spare parts provider Dalkos Co Ltd (Dalkos) has orchestrated a transnational sanctions evasion scheme to deceive foreign machinery manufacturers into inadvertently sending machine tools into Russia via third countries. Dalkos customers include Russian companies that produce drones, tanks, and air defense units. Dalkos co-owners Konstantin Svyatoslavovich Kalinov (Kalinov)and Aleksandr Aleksandrovich Pushkov (Pushkov) also own Estonia-based SPE OU, which Dalkos has used to acquire millions of dollars of goods.
Dalkos, Kalinov, and Pushkov were designated pursuant to E.O. 14024 for operating or having operated in the manufacturing sector of the Russian Federation economy. SPE OU was designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Kalinov and Pushkov.
Türkiye-based Manufacturing Equipment Suppliers
Türkiye-based Hidropark Hidrolik Pnomatik San Ve Tic Ltd Sti (Hidropark) sells hydraulic and pneumatic equipment and has supplied computer numerical control (CNC) machine tools and machining centers to Russian end-users. Hidropark has sent shipments totaling over $800,000 to Russia-based end-users, which is more than its reported annual revenue.
Turkiye-based Feva Dis Ticaret Limited Sirketi (Feva) has supplied CNC machine tools to Russian end-users. Feva has sent over 500 shipments to Russia-based end-users, with shipments including manufacturing equipment. U.S.-designated Russian firm Limited Liability Company AK Microtech sought to evade sanctions by purchasing goods through Feva. Feva was established in April 2022.
Hidropark and Feva were designated pursuant to E.O. 14024 for operating or having operated in the manufacturing sector of the Russian Federation economy.
Technopole Procurement Network
On December 22, 2022, the U.S. Department of State designated Technopole Company (Technopole) and the P.P. Shirshov Institute of Oceanology of the Russian Academy of Sciences (Shirshov Institute) pursuant to E.O. 14024 for operating or having operated in the marine sector of the Russian Federation economy. Technopole produces a navigation system for the use of Russian military vessels and provides equipment for a variety of ocean exploration, oceanology, oceanography, and hydrography activities, among others. The Shirshov Institute is the largest Russian oceanology research center. The Shirshov Institute also develops remotely operated and autonomous robotic tools that support the surface and submarine forces of the Russian navy and other Russian government agencies. Russian national Alexander Petrovich Voronkov (Voronkov) has been the Director of Technopole since 2007 and is the 100 percent owner of the company. Russian national Viktor Georgiyevich Spiridonov (Spiridonov) is the Deputy Director of Technopole and is actively involved in Russian procurement of western-origin equipment.
Idronaut S.R.L. (Idronaut) is one of Technopole's foreign partners and facilitates the procurement and sale of equipment, on behalf of Technopole and other Russian military end users, including the Shirshov Institute. Flavio Graziottin (Graziottin) owns Idronaut and has worked to circumvent U.S. and European Union sanctions through Idronaut to acquire equipment for Technopole.
Idronaut and PRC-based company Shanghai Oceanen Environmental Science and Technology Co. (Shanghai Oceanen) have worked to circumvent sanctions on Technopole and have procured equipment on Technopole's behalf. Shanghai Oceanen is the distributor for Idronaut in the PRC and has acted as a middleman to ship Idronaut's equipment to Technopole and the Shirshov Institute. Shanghai Oceanen has historically assisted Technopole in procuring dual-use equipment for Russian end users. In early 2023, Shanghai Oceanen sent a shipment to Technopole containing surveying equipment, including hydrographic, oceanographic, hydrological, meteorological, or geophysical instruments and appliances. PRC national Liu Yang is the Technical Director for Shanghai Oceanen and uses the company to facilitate the procurement of foreign equipment.
Russia-based Technomar offers advanced measurement oceanographic and hydrographic equipment in the fields of oceanography and hydrology from the world's leading manufacturers.
Voronkov and Spiridonov were designated pursuant to E.O. 14024 for having acted or purported to act for or on behalf of, directly or indirectly, Technopole. Idronaut was designated pursuant to E.O.14024 for having materially assisted, sponsored, or provided financial, material, technological or other support for, or goods or services in support of, Technopole and the Shirshov Institute. Graziottin was designated pursuant to E.O. 14024 for having acted or purported to act for or on behalf of, directly or indirectly, Idronaut. Shanghai Oceanen was designated pursuant to E.O. 14024 for having materially assisted, sponsored, or provided financial, material, technological or other support for, or goods or services in support of, Technopole. Liu Yang was designated pursuant to E.O.14024 for having acted or purported to act for or on behalf of, directly or indirectly, Shanghai Oceanen. Technomar was designated pursuant to E.O. 14024 for operating or having operated in the marine sector of the Russian Federation economy.
ANNEX 2: RUSSIA'S DOMESTIC WAR ECONOMY
The following Russia-based persons were designated pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector of the Russian Federation economy:
Russia-based electronic parts wholesaler LLC Semicor is a subsidiary of U.S.-designated LLC Laser Components (Laser Components). LLC Semicor has offered to supply engines on behalf of LLC Laser Components in support of Russian cruise missile development. LLC Semicor was designated pursuant to E.O. 14024 for having materially assisted, sponsored, or provided material, financial, or technological support for, or goods or services to or in support of, Laser Components.
The following Russia-based persons were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy:
ANNEX 3: RUSSIA'S STRATEGIC METALS AND MINING SECTOR
The following Russia-based companies are involved in or provide services to Russia's metals industry.
Russian metals and mining companies
The following Russia-based companies were designated pursuant to E.O. 14024 for operating or having operated in the metals and mining sector of the Russian Federation economy.
Russian metals and mining support services companies
Russia-based Aktsionernoe Obshchestvo Norilsk Avia (Norilsk Avia) provides helicopter transportation services. Norilsk Avia was designated pursuant to E.O. 14024 for operating or having operated in the aerospace sector of the Russian Federation economy.
The following Russia-based entities were designated pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy:
The following Russia-based entities were designated pursuant to E.O. 14024 for operating or having operated in the transportation sector of the Russian Federation economy:
The following Russia-based entities were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy:
The following Russia-based entities were designated pursuant to E.O. 14024 for operating or having operated in the construction sector of the Russian Federation economy:
The following Russia-based entities were designated pursuant to E.O. 14024 for operating or having operated in the engineering sector of the Russian Federation economy:
The following Russia-based entities were designated pursuant to E.O. 14024 for operating or having operated in the manufacturing sector of the Russian Federation economy:
MMK
Russia-based Publichnoe Aktsionernoe Obschestvo Magnitogorskiy Metallurgicheskiy Kombinat (MMK) was designated pursuant to E.O. 14024 for operating or having operated in the metals and mining sector of the Russian Federation economy. MMK is the largest iron and steel works company in Russia and a leading steelmaker globally. OFAC previously designated MMK pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy.
SANCTIONS IMPLICATIONS
As a result of today's action, all property and interests in property of the persons above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or blocked persons are prohibited unless authorized by a general or specific license issued by OFAC, or exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person. Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as from engaging in conduct that evades U.S. sanctions. OFAC's Economic Sanctions Enforcement Guidelines provide more information regarding OFAC's enforcement of U.S. sanctions, including the factors that OFAC generally considers when determining an appropriate response to an apparent violation.
In addition, foreign financial institutions that conduct or facilitate significant transactions or provide any service involving Russia's military-industrial base run the risk of being sanctioned by OFAC. For additional guidance, please see the updated OFAC advisory, "Updated Guidance for Foreign Financial Institutions on OFAC Sanctions Authorities Targeting Support to Russia's Military-Industrial Base," as well as OFAC Frequently Asked Questions (FAQs) 1146-1157.
The power and integrity of OFAC sanctions derive not only from OFAC's ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC's FAQ 897 here. For detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here.
Any persons included on the SDN List pursuant to E.O. 14024 may be subject to additional export restrictions administered by the Department of Commerce, Bureau of Industry and Security (BIS).
For identifying information on the individuals and entities sanctioned today, click here.
###