Finally! OFAC sanctions Russian entities for election meddling, cyber activities

Today, OFAC added the following persons: 

AFANASYEV, Sergei (a.k.a. AFANASYEV, Sergey), Russia; DOB 16 May 1963; Gender Male (individual) [CAATSA – RUSSIA] (Linked To: MAIN INTELLIGENCE DIRECTORATE). 
 
MOLCHANOV, Grigoriy Viktorovich; DOB 01 Jan 1956 to 31 Dec 1956; citizen Russia; Gender Male (individual) [CAATSA – RUSSIA] (Linked To: MAIN INTELLIGENCE DIRECTORATE). 

to a new Russia-related CAATSA sanctions program that previously had no designations. 

Similarly, the following persons:

ASLANOV, Dzheykhun Nasimi Ogly (a.k.a. ASLANOV, Jay; a.k.a. ASLANOV, Jayhoon), Russia; DOB 01 Jan 1990; POB Azerbaijan; Gender Male (individual) [CYBER2] (Linked To: INTERNET RESEARCH AGENCY LLC). 
 
BOGACHEVA, Anna Vladislavovna, Russia; DOB 13 Mar 1988; Gender Female (individual) [CYBER2] (Linked To: INTERNET RESEARCH AGENCY LLC). 
 
BOVDA, Maria Anatolyevna (a.k.a. BELYAEVA, Maria Anatolyevna), Russia; DOB 21 Feb 1986; Gender Female (individual) [CYBER2] (Linked To: INTERNET RESEARCH AGENCY LLC). 
 
BOVDA, Robert Sergeyevich, Russia; DOB 27 Aug 1989; Gender Male (individual) [CYBER2] (Linked To: INTERNET RESEARCH AGENCY LLC). 
 
BURCHIK, Mikhail Leonidovich (a.k.a. ABRAMOV, Mikhail), Russia; DOB 07 Jun 1986; Gender Male (individual) [CYBER2] (Linked To: INTERNET RESEARCH AGENCY LLC). 
 
BYSTROV, Mikhail Ivanovich, Russia; DOB 21 Dec 1958; Gender Male (individual) [CYBER2] (Linked To: INTERNET RESEARCH AGENCY LLC). 
 
KAVERZINA, Irina Viktorovna, Russia; DOB 18 Jul 1986; Gender Female (individual) [CYBER2] (Linked To: INTERNET RESEARCH AGENCY LLC). 
 
KRYLOVA, Aleksandra Yuryevna, Russia; DOB 01 Jul 1986; Gender Female (individual) [CYBER2] (Linked To: INTERNET RESEARCH AGENCY LLC). 
 
PODKOPAEV, Vadim Vladimirovich, Russia; DOB 01 May 1985; Gender Male (individual) [CYBER2] (Linked To: INTERNET RESEARCH AGENCY LLC). 
 
POLOZOV, Sergey Pavlovich, Russia; DOB 13 Oct 1987; Gender Male (individual) [CYBER2] (Linked To: INTERNET RESEARCH AGENCY LLC). 
 
VASILCHENKO, Gleb Igorevich, Russia; DOB 13 Apr 1991; Gender Male (individual) [CYBER2] (Linked To: INTERNET RESEARCH AGENCY LLC). 
 
VENKOV, Vladimir, Russia; DOB 28 May 1990; Gender Male (individual) [CYBER2] (Linked To: INTERNET RESEARCH AGENCY LLC).

and entity: 

INTERNET RESEARCH AGENCY LLC (a.k.a. AZIMUT LLC; a.k.a. GLAVSET LLC; a.k.a. MEDIASINTEZ LLC; a.k.a. MIXINFO LLC; a.k.a. NOVINFO LLC), 55 Savushkina Street, St. Petersburg, Russia [CYBER2].  

were added to the Cyber-related sanctions program.

And the following existing listings were modified to add them to the Cyber program, and some were also added to the CAATSA program:

ALEXSEYEV, Vladimir Stepanovich; DOB 24 Apr 1961; Passport 100115154 (Russia); First Deputy Chief of GRU (individual) [CYBER2] (Linked To: MAIN INTELLIGENCE DIRECTORATE). -to- ALEXSEYEV, Vladimir Stepanovich; DOB 24 Apr 1961; Passport 100115154 (Russia); First Deputy Chief of GRU (individual) [CYBER2] [CAATSA – RUSSIA] (Linked To: MAIN INTELLIGENCE DIRECTORATE). 
 
CONCORD CATERING, Nab. Lieutenant Schmidt D. 7, von Keyserling Mansion, St. Petersburg 119034, Russia; Ulitsa Volkhonka Dom 9, Moscow 119019, Russia [UKRAINE-EO13661]. -to- CONCORD CATERING, Nab. Lieutenant Schmidt D. 7, von Keyserling Mansion, St. Petersburg 119034, Russia; Ulitsa Volkhonka Dom 9, Moscow 119019, Russia [UKRAINE-EO13661] [CYBER2] (Linked To: INTERNET RESEARCH AGENCY LLC). 
 
FEDERAL SECURITY SERVICE (a.k.a. FEDERALNAYA SLUZHBA BEZOPASNOSTI; a.k.a. FSB), Ulitsa Kuznetskiy Most, Dom 22, Moscow 107031, Russia; Lubyanskaya Ploschad, Dom 2, Moscow 107031, Russia [CYBER2]. -to- FEDERAL SECURITY SERVICE (a.k.a. FEDERALNAYA SLUZHBA BEZOPASNOSTI; a.k.a. FSB), Ulitsa Kuznetskiy Most, Dom 22, Moscow 107031, Russia; Lubyanskaya Ploschad, Dom 2, Moscow 107031, Russia [CYBER2] [CAATSA – RUSSIA]
 
GIZUNOV, Sergey (a.k.a. GIZUNOV, Sergey Aleksandrovich); DOB 18 Oct 1956; Passport 4501712967 (Russia); Deputy Chief of GRU (individual) [CYBER2] (Linked To: MAIN INTELLIGENCE DIRECTORATE). -to- GIZUNOV, Sergey Aleksandrovich (a.k.a. GIZUNOV, Sergey); DOB 18 Oct 1956; Gender Male; Passport 4501712967(Russia); Deputy Chief of GRU (individual) [CYBER2] [CAATSA – RUSSIA] (Linked To: MAIN INTELLIGENCE DIRECTORATE). 
 
KOROBOV, Igor (a.k.a. KOROBOV, Igor Valentinovich); DOB 03 Aug 1956; nationality Russia; Passport 100119726 (Russia); alt. Passport 100115101 (Russia); Chief of GRU (individual) [CYBER2] (Linked To: MAIN INTELLIGENCE DIRECTORATE). -to- KOROBOV, Igor Valentinovich (a.k.a. KOROBOV, Igor); DOB 03 Aug 1956; nationality Russia; Gender Male; Passport 100119726 (Russia); alt. Passport 100115101 (Russia); Chief of GRU (individual) [CYBER2] [CAATSA – RUSSIA] (Linked To: MAIN INTELLIGENCE DIRECTORATE). 
 
KOSTYUKOV, Igor (a.k.a. KOSTYUKOV, Igor Olegovich); DOB 21 Feb 1961; Passport 100130896 (Russia); alt. Passport 100132253 (Russia); First Deputy Chief of GRU (individual) [CYBER2] (Linked To: MAIN INTELLIGENCE DIRECTORATE). -to- KOSTYUKOV, Igor Olegovich (a.k.a. KOSTYUKOV, Igor); DOB 21 Feb 1961; Passport 100130896 (Russia); alt. Passport 100132253 (Russia); First Deputy Chief of GRU (individual) [CYBER2] [CAATSA – RUSSIA] (Linked To: MAIN INTELLIGENCE DIRECTORATE). 
 
LIMITED LIABILITY COMPANY CONCORD MANAGEMENT AND CONSULTING (a.k.a. KONKORD MENEDZHMENT I KONSALTING, OOO; a.k.a. LLC CONCORD MANAGEMENT AND CONSULTING; a.k.a. OBSHCHESTVO S OGRANNICHENNOI OTVETSTVENNOSTYU KONKORD MENEDZHMENT I KONSALTING), D. 13 Litera A, Pom. 2-N N4, Naberezhnaya Reki Fontanki, St. Petersburg 191011, Russia; Registration ID 1037843002515 [UKRAINE-EO13661]. -to- LIMITED LIABILITY COMPANY CONCORD MANAGEMENT AND CONSULTING (a.k.a. KONKORD MENEDZHMENT I KONSALTING, OOO; a.k.a. LLC CONCORD MANAGEMENT AND CONSULTING; a.k.a. OBSHCHESTVO S OGRANNICHENNOI OTVETSTVENNOSTYU KONKORD MENEDZHMENT I KONSALTING), D. 13 Litera A, Pom. 2-N N4, Naberezhnaya Reki Fontanki, St. Petersburg 191011, Russia; Registration ID 1037843002515 [UKRAINE-EO13661] [CYBER2] (Linked To: INTERNET RESEARCH AGENCY LLC). 
 
MAIN INTELLIGENCE DIRECTORATE (a.k.a. GLAVNOE RAZVEDYVATEL’NOE UPRAVLENIE (Cyrillic: ГЛАВНОЕ РАЗВЕДЫВАТЕЛЬНОЕ УПРАВЛЕНИЕ); a.k.a. GRU; a.k.a. MAIN INTELLIGENCE DEPARTMENT), Khoroshevskoye Shosse 76, Khodinka, Moscow, Russia; Ministry of Defence of the Russian Federation, Frunzenskaya nab., 22/2, Moscow 119160, Russia [CYBER2]. -to- MAIN INTELLIGENCE DIRECTORATE (a.k.a. GLAVNOE RAZVEDYVATEL’NOE UPRAVLENIE (Cyrillic: ГЛАВНОЕ РАЗВЕДЫВАТЕЛЬНОЕ УПРАВЛЕНИЕ); a.k.a. GRU; a.k.a. MAIN DIRECTORATE OF THE GENERAL STAFF; a.k.a. MAIN INTELLIGENCE DEPARTMENT), Khoroshevskoye Shosse 76, Khodinka, Moscow, Russia; Ministry of Defence of the Russian Federation, Frunzenskaya nab., 22/2, Moscow 119160, Russia [CYBER2] [CAATSA – RUSSIA]
 
PRIGOZHIN, Yevgeniy Viktorovich (a.k.a. PRIGOZHIN, Evgeny), Russia; DOB 1961; Gender Male (individual) [UKRAINE-EO13661]. -to- PRIGOZHIN, Yevgeniy Viktorovich (a.k.a. PRIGOZHIN, Evgeny), Russia; DOB 01 Jun 1961; Gender Male (individual) [UKRAINE-EO13661] [CYBER2] (Linked To: INTERNET RESEARCH AGENCY LLC).

Additionally, General License 1 for the Cyber-related sanctions program, which permits certain activities with the FSB, was replaced with General Licence 1A. The changes are cosmetic, adding CAATSA to the regulatory environment of the license.

And finally, updated FAQs were released for both the General License:

501. What does General License 1A (GL 1A), “Authorizing Certain Transactions with the Federal Security Service,” authorize?

GL 1A authorizes transactions with the Federal Security Service (a.k.a. Federalnaya Sluzhba Bezopasnosti) (a.k.a. FSB) that are necessary and ordinarily incident to requesting, receiving, utilizing, paying for, or dealing in certain licenses and authorizations for the importation, distribution, or use of certain information technology products in the Russian Federation.  It also authorizes transactions necessary and ordinarily incident to compliance with rules and regulations administered by, and certain actions or investigations involving, the FSB.

This general license does not authorize U.S. persons to engage in transactions with the FSB except for the limited purposes described above, nor does it authorize the exportation, reexportation, or provision of any goods, technology, or services to the Crimea region of Ukraine. 

A prior version of this general license was issued on February 2, 2017 (GL 1).  On March 15, 2018, GL 1 was amended and reissued as GL 1A to ensure the scope of activities already authorized with respect to the FSB is not affected by the designation of the FSB under Section 224 of the Countering America’s Adversaries Through Sanctions Act (CAATSA).  The changes to GL 1 are limited to adding CAATSA authorities.  GL 1A replaces and supersedes GL 1 effective March 15, 2018.  [03-15-2018]


502. What sanctions remain in place on the FSB following the issuance of GL 1A?

GL 1A only authorizes certain transactions with the FSB acting in its administrative and law enforcement capacities.  The GL was issued in order to ensure that U.S. persons engaging in certain business activities in Russia that are not otherwise prohibited are not unduly impacted.  All other transactions involving any property subject to U.S. jurisdiction or within the possession or control of U.S. persons in which the FSB has an interest, including all other transactions directly or indirectly with the FSB, remain prohibited unless exempt or otherwise authorized by OFAC. [03-15-2018]


503. Does GL 1A authorize the exportation of hardware or software directly to the FSB, or where the FSB is the end user of such hardware and software?

No. GL 1A does not authorize the export of any goods, technology, or services directly or indirectly to the FSB or any other blocked person or entity, except for the limited purposes of complying with certain rules, regulations, and investigations involving the FSB or requesting certain licenses or authorizations for the importation, distribution, or use of information technology products in the Russian Federation. [03-15-2018]


504. I understand that travel to Russia involves clearing Russian border control, which is part of the FSB.  Do I need a license from OFAC to travel to Russia, or to clear Russian customs?

No, the sanctions on the FSB do not apply to transactions by U.S. persons that are ordinarily incident to travel to or from Russia, including those transactions required to enter into or exit the country (i.e., complying with Russian border control requirements). [03-15-2018]

 and for the CAATSA program:

546. In section 10(a)(2)(A) of SSIDES, are persons “subject to sanctions imposed by the United States with respect to the Russian Federation” limited to persons listed on OFAC’s Specially Designated Nationals and Blocked Persons (SDN) List, or does it include persons identified on the Sectoral Sanctions Identifications (SSI) List as well?
 
For purposes of implementing section 10(a)(2)(A) of SSIDES, OFAC will interpret the phrase “subject to sanctions imposed by the United States with respect to the Russian Federation” to be persons subject to sanctions under SSIDES, as amended, UFSA, as amended, provisions of CAATSA with respect to the Russian Federation, and any covered Executive order as defined in Section 10(f)(1) of SSIDES.  Persons “subject to sanctions imposed by the United States with respect to the Russian Federation” include persons listed on either the SDN or SSI List, as well as persons subject to sanctions pursuant to OFAC’s 50 percent rule.  [03-15-2018]

And, if you are unfamiliar, as Mr. Watchlist was, SSIDES stands for Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014…

Links:

OFAC Notice

Cyber-Related General License 1A

FAQs – General License 1A-relatedCAATSA-related

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