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With Over 300 Sanctions, U.S. Targets Russia’s Circumvention and Evasion, Military

Oct 15, 2023

U.S. Actions, With Touchpoints in More Than 20 Jurisdictions, Coordinated with G7 and Other International Partners

WASHINGTON – Today, the United States, in coordination with the G7 and other international partners, is strengthening the unprecedented global sanctions and other restrictive economic measures to further degrade the Russian Federation's capacity to wage war against Ukraine. The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) is implementing new commitments made at the G7 Leaders’ Summit to hold Russia accountable for its war.

"From the beginning of President Putin's illegal and unprovoked war, our global coalition has focused on supporting Ukraine while degrading Russia's ability to conduct its invasion," said Secretary of the Treasury Janet L. Yellen. "Our collective efforts have cut Russia off from key inputs it needs to equip its military and is drastically limiting the revenue the Kremlin receives to fund its war machine. Today's actions will further tighten the vise on Putin's ability to wage his barbaric invasion and will advance our global efforts to cut off Russian attempts to evade sanctions."

OFAC's sanctions on 22 individuals and 104 entities, with touchpoints in more than 20 countries or jurisdictions, target those attempting to circumvent or evade sanctions and other economic measures against Russia, the channels Russia uses to acquire critical technology, its future energy extraction capabilities, and Russia's financial services sector. Additionally, OFAC is expanding sanctions authorities to target new sectors of Russia's economy and sever Russia's access to new categories of services. The U.S. Department of State also designated or identified as blocked property almost 200 individuals, entities, vessels, and aircraft. The U.S. Department of Commerce is significantly expanding the territorial reach and categories covered by its export controls and adding 71 entities to its Entity List to prevent Russia from accessing goods it needs for the battlefield.

Also today, Treasury's Financial Crimes Enforcement Network (FinCEN) and Commerce's Bureau of Industry and Security (BIS) issued a joint supplemental alert urging continued vigilance for potential Russian export control evasion. This supplemental alert builds on FinCEN and BIS's first joint alert, issued in June 2022, and provides financial institutions additional information with respect to new BIS export control restrictions relating to Russia. The alert also reinforces ongoing U.S. government engagements and initiatives designed to further constrain and prevent Russia from accessing needed technology and goods to supply and replenish its military and defense industrial base. It details evasion typologies and identifies additional transactional and behavioral red flags to assist financial institutions.

OFAC is enhancing and expanding its use of Russia-related sanctions authorities by issuing a determination that identifies the architecture, engineering, construction, manufacturing, and transportation sectors of the Russian Federation economy pursuant to section 1(a)(i) of Executive Order (E.O.) 14024. This determination allows for sanctions to be imposed on any individual or entity determined to operate or have operated in any of those sectors and expands the United States’ ability to swiftly impose additional economic costs on Russia for its war of choice against Ukraine. This action complements existing sanctions authorities against those that operate or have operated in the metals and mining, quantum computing, accounting, trust and corporate formation, management consulting, aerospace, marine, electronics, financial services, technology, and defense and related materiel sectors of the Russian Federation economy. The new sectoral determinations are being made in support of the G7 Leaders’ commitment today to further target those operating in sectors key to Russia's military-industrial base.

In addition, OFAC is taking action to sever Russia's access to certain services from the United States or by U.S. persons, matching measures taken by the United Kingdom and the European Union. Today, OFAC issued a determination pursuant to E.O. 14071 prohibiting the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of architecture services or engineering services to any person located in the Russian Federation. This prohibition will take effect beginning at 12:01 a.m. eastern daylight time on June 18, 2023.

In conjunction with these determinations, OFAC is issuing new guidance.

OFAC is also amending Directive 4 under E.O. 14024, "Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the national Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation," to require U.S. persons to report to OFAC any property in their possession or control in which the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation has an interest.

This reporting requirement is designed to provide additional information and fidelity on the Russian sovereign assets immobilized in U.S. jurisdiction. It is consistent with a similar measure recently adopted by the European Union and implements the G7 Leaders’ commitment today to take steps to fully map holdings of Russia's sovereign assets that will remain immobilized in G7 jurisdictions until Russia pays for the damage it has caused to Ukraine.

Increasingly, as the world closes its doors to Russian business in response to Russia's war of aggression against Ukraine, Russia has turned to evasion and circumvention to attempt to acquire the goods its military-industrial complex desperately needs. These efforts are sometimes directed by Russia's intelligence services and defense companies, who stand to benefit from the procurement of hard-to-get goods. These targets implement the G7 Leaders’ call for third countries or other international actors who seek to evade or undermine economic restrictions to cease providing material support to Russia's war, or face severe costs.

On February 24, 2023, OFAC designated Swiss-Italian businessman Walter Moretti (Moretti) and members of his network pursuant to E.O. 14024. Moretti and his colleagues have covertly procured sensitive technologies and equipment for Russia's intelligence services and military. Today, OFAC designated five additional members of Moretti's network.

Germany national Dirk Troendle (Troendle) has assisted Moretti in the procurement of sensitive technologies and equipment for Russia's intelligence services and Russia's military.

Mavasal Impex Private Limited (Mavasal) and Innoedge Cloudserve Private Limited (Innoedge) are India-based companies used by Moretti and his network to source and procure technology for Russian end-users. Specifically, under the direction of Moretti and his colleagues, Mavasal and Innoedge purchase advanced technology and then re-sell it to Russian state-owned enterprises, including entities involved in Russian nuclear weapons-related research and development.

India national Sharda Subramaniam (Subramaniam) has helped procure equipment and technology, including military materiel, from India to Russia on behalf of Moretti. India national Surya Dutta (Dutta) has sourced and coordinated the shipment of various goods, including military gear, to Russia on Moretti's behalf.

Troendle was 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, Moretti, a person whose property and interests in property are blocked pursuant to E.O. 14024.

Mavasal and Innoedge were designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, the Government of the Russian Federation.

Subramaniam and Dutta were designated pursuant to E.O. 14024 for having acted or purported to act for or on behalf of, directly or indirectly, Moretti, a person whose property and interests in property are blocked pursuant to E.O. 14024.

Liechtenstein-based company Trade Initiative Establishment (TIE) has been involved in the procurement of semiconductor and nanotechnology production equipment for U.S.-designated Russian entities since at least 2012.

Limited Liability Company TBS (TBS) is a technology company located in Moscow that provides testing systems for the microelectronic industry. Russia's intelligence services have used TBS to enable payments and ship equipment on behalf of Russian customers. Russian Federation national Natalya Yuryevna Vinogradova (Vinogradova) is the majority shareholder and general director of TBS.

IGT Intergestions Trust Reg (IGT), a Liechtenstein-based trust company also engaging in business, accounting, and management consulting, coordinated between TIE and TBS and European technology firms and banks in order to procure technology equipment for U.S.-designated Russian end-users without raising suspicion.

Russian Federation nationals Andrey Vladimirovich Timoshin (Timoshin) and Anton Yuryevich Lestafye (Lestafye) worked with TBS, TIE, and IGT to procure semiconductor and nanotechnology production equipment for U.S.-designated Russian entities. Timoshin and Lestafye's procurement activity was directed by Russia's intelligence services.

Liechtenstein national Pascal Dominik Buechel (Buechel) is the general director of TIE and a director of IGT. While employed by IGT, Buechel conducted business for TIE.

TBS, TIE, Vinogradova, Timoshin, and Lestafye were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy.

IGT was designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, TIE.

Buechel 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 TIE.

Netherlands national Edwin Onno Van Ingen (Van Ingen), through his company Ronin Management B.V. (Ronin), is a primary Europe-based procurement agent for Russian laboratories focused on nuclear weapon design and development as well as research on advanced conventional weapons technologies. Russia's intelligence services often task Van Ingen to solicit offers and procure technologies such as advanced manufacturing, scientific, and measuring equipment. Van Ingen then approaches manufacturers and resellers and, in many cases, helps mask the real end-user of the equipment being bought and helps organize the equipment's transshipment to Russia.

Van Ingen was designated pursuant to E.O. 14024 for having acted or purported to act for or on behalf of, directly or indirectly, the Government of the Russian Federation.

Ronin was designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, the Government of the Russian Federation.

Van Ingen has two other Netherlands-based companies, Pro Rata Solutions B.V. (Pro Rata), a business services provider, and Delta Technical and Scientific Instruments B.V. (Delta Technical), a wholesaler.

Pro Rata and Delta Technical 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, Van Ingen.

On March 3, 2022, Radioavtomatika LLC (Radioavtomatika), an entity that specializes in procuring foreign items for Russia's defense industry, was designated pursuant to E.O. 14024. Additional sanctions actions since then have targeted companies based in Armenia, the People's Republic of China, Türkiye, and Uzbekistan procuring components for Radioavtomatika, as well as individuals associated with Radioavtomatika.

Today, OFAC is targeting additional individuals and entities tied to Radioavtomatika.

Russian Federation national Pavel Viktorovich Akifyev (Akifyev) has been coordinating with Radioavtomatika to procure electronic components by way of various intermediary firms, including Czechia-based Versvet SRO (Versvet) and Russia-based LLC Symphony (Symphony)—both of which are owned and directed by Russian Federation national Svetlana Yuryevna Verkhovtseva (Verkhovtseva)—and Akifyev's Russia-based companies Trust Logistic and OOO Trast Lodzhistiks Grupp (TLG). Since Radioavtomatika was added to OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List), it has repeatedly attempted to utilize such intermediaries to import foreign electronic components into Russia in an effort to evade sanctions. Components purchased by these intermediaries have contributed to the development of Russian advanced conventional weapons systems, among other Russian military projects. Trust Logistic and TLG were previously added to the Department of Commerce's Entity List.

Akifyev, Symphony, and Verkhovtseva were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy.

Trust Logistic and TLG were designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Akifyev.

Versvet was designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Verkhovtseva.

OFAC is also targeting the channels Russia uses to access inputs that allow it to rebuild its war machine. In particular, OFAC is disrupting Russia's ability to acquire foreign-made semiconductors and other microelectronics necessary for the maintenance and development of its military-industrial complex.

With its supply chains decimated by the economic measures taken by the United States in concert with partners from around the world, Russia has been forced to adopt other means and methods to acquire the technology it desperately needs. One of the most common tactics, detailed in the March 2023 Compliance Note, is the use of third-party intermediaries or transshipment points to circumvent restrictions, disguising the involvement of persons on the SDN List or entities on the Department of Commerce's Entity List in transactions, and obscuring the true identities of Russian end-users. As noted in FAQ 1092, OFAC will continue to target Russia's efforts to resupply and sustain its war of aggression against Ukraine, including any foreign persons who assist Russia in those efforts.

These actions also implement the G7 Leaders’ commitment today to starve Russia of G7 technology, industrial equipment, and services that support its war machine.

Russia's Ostec Group imports and distributes quantum and semiconductor technologies to Russian defense entities, specializing in the supply of foreign microelectronics and production equipment to the Russian military-industrial complex.

Today, OFAC designated 12 entities that comprise the Ostec Group, as well as two associated individuals.

The following Russia-based Ostec Group companies were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy:

OFAC also designated Russian Federation nationals Vadim Veniaminovich Garshin (Garshin) and Aleksandr Gennadievich Razorenov (Razorenov), who together own the companies in the Ostec Group. Razorenov is also the director of Ostec Enterprise Ltd. Garshin and Razorenov were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy.

Garshin and Razorenov also own other companies in the Ostec Group, including Ostec-Arttool Ltd (Ostec-Arttool), GEFESD Ltd (GEFESD), and Limited Liability Company Businesspromestate (Businesspromestate).

Ostec-Arttool, GEFESD, and Businesspromestate were designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Garshin and Razorenov.

Poland-based freight company Inter-Trans Spolka z Ograniczona Odpowiedzialnoscia (Inter-Trans) has facilitated hundreds of shipments of electronic components and other goods bound for Ostec Group companies, including since the beginning of Russia's invasion of Ukraine. Poland national Jacek Romuald Swiniarski (Swiniarski) holds commercial power of attorney and acts as a proxy for Inter-Trans.

Inter-Trans is owned by Belarus national Evgueni Kostiouk (Kostiouk), who is also the Chief Executive Officer and sole board member of the company. Kostiouk is also the ultimate owner of Germany-based freight forwarder Belmagistralavtotrans Speditions GmbH (BMA Spedition), which arranges transports between Western Europe and Russia, Belarus, and other former Soviet republics. BMA Spedition has also been involved in the transfer of equipment to the Ostec Group.

Inter-Trans and Kostiouk were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy. Swiniarski was designated pursuant to E.O. 14024 for having acted or purported to act for or on behalf of, directly or indirectly, Inter-Trans. BMA Spedition was designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Kostiouk.

Koneisto International Oy (Koneisto) is a Finland-based technology company that offers clients a wide variety of goods and services, including computer components, laboratory equipment, surveillance and security equipment, and metal processing machinery. Koneisto has shipped optoelectronic goods and laboratory equipment to two U.S.-designated Russian technology companies, PSV Technologies LLC and Limited Liability Company Promtekhekspert. Russian Federation national Alexander Sakulin (Sakulin) is the managing director of Koneisto and Finland national Evgenia Dremova (Dremova) is a deputy board member of Koneisto. Dremova's company Hi-Tech Koneisto International Oy (Hi-Tech Koneisto) shares an address with Koneisto.

Koneisto, Sakulin, and Dremova were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy. Hi-Tech Koneisto was designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Dremova.

Estonia-registered Elmec Trade OU (Elmec Trade) has shipped millions of dollars of electronics to Russia since the beginning of Russia's full-scale invasion of Ukraine. In particular, Elmec Trade has shipped U.S.-manufactured electronic components to Russian companies Limited Liability Company Kvazar (Kvazar), an importer of U.S.-manufactured electronic components, and Limited Liability Company Spetsvoltazh (Spetsvoltazh), an importer and distributor of U.S.-, Europe-, and Asia-made electronic components.

Elmec Trade, Kvazar, and Spetsvoltazh were designated pursuant to E.O. 14024 for operating or having operated in the electronics sector of the Russian Federation economy.

Despite the economic restrictions in place to prevent Russia from importing sensitive and dual-use goods, Russian companies continue to attempt to import foreign-made technology such as semiconductors and related equipment and components. Foreign persons should be aware that doing business with Russian technology and electronics companies puts them at risk of being sanctioned themselves.

Today, OFAC is designating more than 30 companies that import, ship, or manufacture electronics components, semiconductors, and microelectronics to or in Russia. OFAC designated the following Russia-based companies pursuant to E.O. 14024 for operating or having operated in the electronics sector of the Russian Federation economy:

Additionally, OFAC designated Russian Federation national Anton Anatolyevich Efimov (Efimov), the owner of Avesto OOO and Inelso OOO. Efimov also owns a firm in Estonia, Elfaro OU, that was formerly known as OU Inelso.

Efimov was designated pursuant to E.O. 14024 for operating or having operated in the electronics sector of the Russian Federation economy. Elfaro OU was designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Efimov.

Lastly, Brand Server Options (BSO) is a Russia-based supplier of components and spare parts for server equipment. BSO was designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy.

Building on the continued success of the G7 price cap coalition in reducing Russia's energy revenue while mitigating spillover effects on global energy security, OFAC is taking targeted action to limit Russia's future extractive capabilities in support of additional commitments made by G7 Leaders today. Today's sanctions target training grounds for Russia's future energy specialists, the Russian research institutes where new extraction technologies are developed, Russian companies that facilitate drilling and mining operations, and firms that attract and advise on investment in Russia's energy industry.

Russia-based Federal State Budget Educational Institution of Higher Education Saint-Petersburg Mining University (SPMI) researches the extraction and processing of raw materials. SPMI works closely with oil and gas companies to develop extraction strategies, and SPMI's students are directly recruited by Russian companies to work in the oil and gas industry. Additionally, SPMI has historically directly supported Russian Federation military efforts by developing new metals technologies for use in war.

Russian Federation national Vladimir Stefanovich Litvinenko (Litvinenko), the current rector of SPMI, was installed in his position by U.S.-designated Russian President Vladimir Vladimirovich Putin (Putin) in 1994. Litvinenko also served as Putin's regional campaign manager on three separate occasions. The Litvinenko family is currently worth several billion dollars.

Russia-based Federal State Budgetary Educational Institution of Higher Education Sergo Ordzhonikidze Russian State University for Geological Prospecting (MGRI) works on geological exploration technology, with a focus on preparing specialists for the oil and gas industry.

Russia-based State Budgetary Educational Institution of Higher Education Almetyevsk State Oil Institute (ASOI) helps companies in the Russian oil and gas industry with technology development.

Federal State Budgetary Educational Institution of Higher Education Grozny State Oil Technical University Named After Academician M.D. Millionshchikov (GSOTU) is the oldest specialized oil university in Russia. GSOTU conducts technical training and studies involving oil and gas production.

Russia-based Federal State Budgetary Educational Institution Of Higher Vocational Education Gubkin Russian State University Of Oil And Gas (Gubkin) develops technologies to improve the efficiency of Russia's oil and gas industries and reduce their dependence on imported supplies.

SMPI, MGRI, ASOI, GSOTU, and Gubkin were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy.

Litvinenko 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 SPMI. Additionally, Litvinenko was designated pursuant to E.O. 14024 for operating or having operated in the metals and mining sector of the Russian Federation economy.

Russia-based research institute Gazprom VNIIGAZ, OOO (VNIIGAZ) is the main research center for Public Joint Stock Company Gazprom, which is subject to prohibitions pursuant to Directive 4 of Executive Order 13662 and Directive 3 of Executive Order 14024. VNIIGAZ develops new technologies for Russia's oil and gas industry.

Russia-based research institute The Federal State Unitary Enterprise V.A. Kargin Scientific-Research Institute of Chemistry and Technology of Polymers With a Pilot Production Plant (NII Polymerov) develops polymers for Russia's oil and gas industry as well as for Russia's military-industrial complex.

Russia-based Institute of Petroleum Chemistry Siberian Branch of The Russian Academy of Sciences (IPC SB RAS) researches and develops advanced technologies for enhanced oil recovery, preparation, transportation, and refining.

Russia-based Siberian Scientific Research Institute of Geology Geophysics and Mineral Raw Material Joint Stock Company (SNIIGGIMS JSC) is a large state-owned research institute in Siberia focused on finding oil and gas deposits. SNIGGIMS JSC performs exploration activities, processes seismic data, and provides scientific support to well drilling.

Russia-based, state-owned All Russia Petroleum Research Exploration Institute Joint Stock Company (VNIGRI JSC) has contributed to Russia's national economy through the discovery of oil and gas deposits.

Russia-based, state-owned All Russian Scientific Research Institute of Geophysical Prospecting Joint Stock Company (VNIIGEOFIZIKA JSC) is involved in prospecting and exploring for oil and gas fields.

Russia-based, state-owned Energy Research Institute of The Russian Academy of Sciences (INEI RAN) provides scientific analysis in order to forecast and develop Russia's national energy policy and markets.

VNIIGAZ, NII Polymerov, and IPC SB RAS were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy.

SNIIGGIMS JSC, VNIGRI JSC, VNIIGEOFIZIKA JSC, and INEI RAN were designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, the Government of the Russian Federation.

Russia-based Gazpromneft Noyabrsk Oil and Gas Geophysics Limited Liability Company (Gazpromneft NNGGF) offers technology services for drilling wells.

Russia-based Mashoil Limited Liability Company (Mashoil) supplies hydraulic fracturing equipment and equipment for mobile drilling rigs and directional drilling. Mashoil also manufactures machinery for mining, quarrying, and construction.

Russia-based drilling company JSC NGT (NGT) produces downhole drilling equipment for the oil and gas industry.

Russia-based Oil Enerdzhi Limited Liability Company (Oil Enerdzhi) is involved in the production of additives for hydraulic fracturing. Oil Enerdzhi also manufactures and sells machinery for mining and construction.

Russia-based Tatburneft Limited Liability Company (Tatburneft) specializes in drilling wells and other mining support activities.

Russia-based Public Joint Stock Company Tyazhpressmash (Tyazhpressmash) is a leading machine building company that operates steel and iron forges. Tyazhpressmash also manufactures mining machinery.

Russia-based Uralmash Oil and Gas Equipment Holding Limited Liability Company (Uralmash) is the largest manufacturer of drilling rigs for deep exploration drilling in Russia.

Gazpromneft NNGGF was designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy.

Mashoil, NGT, Oil Enerdzhi, Tatburneft, and Tyazhpressmash were designated pursuant to E.O. 14024 for operating or having operated in the metals and mining sector of the Russian Federation economy.

Uralmash was designated pursuant to E.O. 14024 for operating or having operated in the manufacturing sector of the Russian Federation economy.

Russia-based UT IT Novaya Industriya OOO (New Industry Ventures) is a venture capital firm backed by Russian state-owned enterprises that invests in companies developing breakthrough technologies and equipment for Russia's energy industry. New Industry Ventures was designated pursuant to E.O. 14024 for operating or having operated in the financial services and technology sectors of the Russian Federation economy.

Russia-based Vygon Consulting (Vygon) is an independent strategic consulting company that advises companies and public authorities on strategic investment decisions in Russia's energy industry. Vygon was designated pursuant to E.O. 14024 for operating or having operated in the management consulting sector of the Russian Federation economy.

OFAC is also taking additional measures to disrupt the financing of Russia's war machine to implement G7 leaders’ commitment to further curtail Russia's use of the international financial system to bolster its war against Ukraine and to target those willfully supporting the financing of Russia's war.

Dubai, United Arab Emirates (UAE)-headquartered Huriya Private FZE LLE (Huriya) is a private equity and corporate structuring entity heavily involved in moving Russian finance into the UAE and money laundering. Since Russia's full-scale invasion of Ukraine in 2022, Huriya began working quickly to move Russian assets into structures protecting them from sanctions. Huriya also helped high-net-worth Russian Federation nationals procure non-Russian passports under assumed names to avoid financial scrutiny and sanctions.

Ireland national John Desmond Hanafin (Hanafin) is the founder and Chief Executive Officer of Huriya. Hanafin facilitated the movement of Russian money into the UAE through Huriya. Hanafin, with assistance from corrupt government officials, also procured fraudulent passports for Russian clients wanting to hide their Russian nationality.

Huriya and Hanafin were designated pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy. Hanafin was also 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 Huriya.

Hanafin's firms Cyprus-based Huriya Private Cyprus Ltd and Hong Kong-based Gold Miles Limited were designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Hanafin.

Aquila Capital Group (ACG), founded and led by Russian Federation national Sergey Yevgenyevich Velichko (Velichko), is a Moscow, Russia-based investment banking firm. ACG and its Russian Federation national employee Yulia Aleksandrovna Sergeeva (Sergeeva) worked with Hanafin to start operations in the UAE and open accounts with UAE banks.

ACG, Velichko, and Sergeeva were designated pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy.

Switzerland-headquartered DuLac Capital Ltd (DuLac Capital) is an asset management company and multi-family office with branches in both Moscow and Saint Petersburg, Russia. Switzerland national Anselm Oskar Schmucki (Schmucki) is DuLac Capital's Moscow branch chief and regional head for Russia, the Commonwealth of Independent States, and the UAE. Schmucki, who is based in the UAE, offers a variety of services, including investment management, in Russia, Switzerland, Cyprus, and the UAE. Schmucki controls a global network of shell companies and has had close financial relationships with an individual charged with financial crimes and a company with suspected links to Russian organized crime and money laundering. Schmucki has also facilitated the sale of tens of millions of dollars of gold bullion.

Schmucki owns or controls more than a dozen companies around the world, including Russia-based East Star Investments Limited and Limited Liability Company Novenko Russlend; Malta-based RB Holding Limited and RB Consulting Limited; Cyprus-based Robarin Ltd; Singapore-based Wealthing Holding PTE Ltd; Hong Kong-based Welmart Group Limited and Kraverton Construction and Development Limited; Estonia-based Schloss Holding OU, Cryptovenience OU, and Cryptanet OU; and United Kingdom-based Saling Development LP, Welmart Group LP, and Kraverton LP. Welmart Group Limited is an apparent shell company likely used by Schmucki to purchase diamonds.

DuLac Capital and Schmucki were designated pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy.

East Star Investments Limited, Limited Liability Company Novenko Russlend, RB Holding Limited, RB Consulting Limited, Robarin Ltd, Wealthing Holding PTE Ltd, Welmart Group Limited, Kraverton Construction and Development Limited, Schloss Holding OU, Cryptovenience OU, Cryptanet OU, Saling Development LP, Welmart Group LP, and Kraverton LP were designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Schmucki.

The Foreign Intelligence Service of the Russian Federation (SVR) is a Government of the Russian Federation intelligence agency. The SVR was designated pursuant to E.O. 14024 for being a political subdivision, agency, or instrumentality of the Government of the Russian Federation.

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.

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 Frequently Asked Question 897 here. For detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here.

For identifying information on the individuals and entities sanctioned or property identified today, click here.

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