August 21, 2018: Double-barreled OFAC designations of Russian targets under Cyber, North Korean programs

On Tuesday, OFAC made two significant sets of sanctions designations. First, they designated the following persons: 

NAGIBIN, Anton Aleksandrovich, Russia; DOB 20 May 1985; POB Leningrad, Russia; Gender Male; Passport 712413714 (Russia) (individual) [CYBER2] (Linked To: DIVETECHNOSERVICES). 
 
TSAREVA, Marina Igorevna, Russia; DOB 09 Nov 1973; POB Krasnoyarsk, Russia; nationality Russia; Gender Female; Passport 711002398 (Russia) (individual) [CYBER2] (Linked To: DIVETECHNOSERVICES; Linked To: VELA-MARINE LTD.).

and entities:  

LACNO S.R.O., Cintorinska 9, Bratislava 81108, Slovakia; D-U-N-S Number 361680273; V.A.T. Number SK2024170423 (Slovakia) [CYBER2] (Linked To: DIVETECHNOSERVICES). 
 
VELA-MARINE LTD. (Cyrillic: OOO ВЕЛА-МАРИН), Saint Petersburg, Russia; Website http://vela-marine.ru [CYBER2] (Linked To: DIVETECHNOSERVICES).

under its cyber-related sanctions.

And Treasury issued this press release about these designations:

Treasury Targets Attempted Circumvention of Sanctions

 
August 21, 2018

Washington –Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is targeting Russian actors’ efforts to circumvent U.S. sanctions.  This action was taken pursuant to authority provided under Executive Order (E.O.) 13694, “Blocking Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities,” as amended, and as codified by the Countering America’s Adversaries Through Sanctions Act (CAATSA), to designate two entities and two Russian individuals in order to counter attempts to evade U.S. sanctions.  

“The Treasury Department is disrupting Russian efforts to circumvent our sanctions,” said Steven T. Mnuchin, Secretary of the Treasury.  “Today’s action against these deceptive actors is critical to ensure that the public is aware of the tactics undertaken by designated parties and that these actors remain blocked from the U.S. financial system.”     

As a result of today’s action, all property and interests in property of the designated persons subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.  

DESIGNATED ENTITIES AND INDIVIDUALS

The individuals and entities identified below are being designated based on the actions they undertook for Divetechnoservices, a Russian entity sanctioned on June 11, 2018 pursuant to E.O. 13694, as amended, for procuring a variety of underwater equipment and diving systems for Russian government agencies, to include the Federal Security Service (FSB).  The FSB was sanctioned on December 28, 2016, pursuant to E.O. 13694, as amended, and on March 15, 2018, pursuant to CAATSA Section 224.

Vela-Marine Ltd. was designated pursuant to E.O. 13694, as amended, for having attempted to act or purported to act for or on behalf of Divetechnoservices.  As of July 2018, Divetechnoservices utilized Vela-Marine Ltd. in an attempt to circumvent U.S. sanctions.

Marina Igorevna Tsareva (Tsareva) was designated pursuant to E.O. 13694, as amended, for having acted for or on behalf of Divetechnoservices and Vela Marine Ltd.  Tsareva has worked as an Import Manager for Divetechnoservices and attempted to help Divetechnoservices circumvent U.S. sanctions through Vela-Marine Ltd.

Anton Aleksandrovich Nagibin (Nagibin) was designated pursuant to E.O. 13694, as amended, for having acted for or on behalf of Divetechnoservices.  As of July 2018, Nagibin was a Divetechnoservices’ employee involved in helping the company attempt to circumvent U.S. sanctions.

Lacno S.R.O. was designated pursuant to E.O. 13694, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, Divetechnoservices.  As of May 2018, Lacno S.R.O., which is based in Slovakia, attempted to facilitate a payment for over $20,000 on behalf of Divetechnoservices.  As of April 2018, Divetechnoservices planned to utilize Lacno S.R.O. to purchase equipment.

Additionally, the following Russian entities: 

GUDZON SHIPPING CO LLC (a.k.a. LLC GUDZON SHIPPING CO; a.k.a. OOO GUDZON SHIPPING CO; a.k.a. SK GUDZON, OOO), ul Tigorovaya 20A, Vladivostok, Primorskiy kray 690091, Russia; Company Number IMO 5753988 [DPRK4]. 
 
PRIMORYE MARITIME LOGISTICS CO LTD (a.k.a. “PML CO LTD”), 01 ul Tigorovaya 20A, Vladivostok, Primorskiy kray 690091, Russia; Company Number IMO 5993381 [DPRK4]. 
 
and Russian cargo vessels: 

BELLA Russia flag; Vessel Registration Identification IMO 8808264 (vessel) [DPRK4] (Linked To: GUDZON SHIPPING CO LLC). 
 
BOGATYR Russia flag; Vessel Registration Identification IMO 9085730 (vessel) [DPRK4] (Linked To: GUDZON SHIPPING CO LLC). 
 
NEPTUN Russia flag; Vessel Registration Identification IMO 8404991 (vessel) [DPRK4] (Linked To: GUDZON SHIPPING CO LLC). 
 
PARTIZAN Russia flag; Vessel Registration Identification IMO 9113020 (vessel) [DPRK4] (Linked To: GUDZON SHIPPING CO LLC). 
 
PATRIOT Russia flag; Vessel Registration Identification IMO 9003550 (vessel) [DPRK4] (Linked To: PRIMORYE MARITIME LOGISTICS CO LTD; Linked To: GUDZON SHIPPING CO LLC). 
 
SEVASTOPOL Russia flag; Vessel Registration Identification IMO 9235127 (vessel) [DPRK4] (Linked To: GUDZON SHIPPING CO LLC). 

were designated under the North Korean sanctions program.

And Treasury issued this press release about the North Korean program designations:

Treasury Targets Russian Shipping Companies for Violations of North Korea-related United Nations Security Council Resolutions

 
August 21, 2018

WASHINGTON – The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced North Korea-related designations, continuing the implementation of existing United Nations (UN) and U.S. sanctions.  Today’s action against two entities and six vessels was taken pursuant to Executive Order 13810 of September 20, 2017, and targets persons involved in the ship-to-ship transfer of refined petroleum products with North Korea-flagged vessels, an activity expressly prohibited by the UN Security Council (UNSC).

“Ship-to-ship transfers with North Korea-flagged vessels from Russia or elsewhere of any goods being supplied, sold, or transferred to or from the DPRK are prohibited under the UN Security Council resolutions on North Korea and are sanctionable under U.S. law,” said Treasury Secretary Steven Mnuchin.  “Consequences for violating these sanctions will remain in place until we have achieved the final, fully verified denuclearization of North Korea.”

Today OFAC designated Vladivostok, Russia-based shipping companies Primorye Maritime Logistics Co Ltd (Primorye) and Gudzon Shipping Co LLC (Gudzon), the registered ship owners and managers of Russia-flagged merchant vessel (M/V) PATRIOT (IMO 9003550).  In early 2018, the PATRIOT conducted two ship-to-ship transfers of oil for the benefit of North Korea, including 1,500 tons of oil to the North Korea-flagged M/V CHONG RIM 2 (IMO 8916293) and 2,000 tons of oil to the North Korea-flagged M/V CHON MA SAN (IMO 8660313).  The ultimate buyer was UN- and U.S.-designated Taesong Bank, a North Korean entity subordinate to the UN- and U.S.-designated Workers’ Party of Korea Office 39, which engages in illicit economic activities for North Korean leadership.  The CHONG RIM 2 was listed by the UN and the United States in March 2016.  The CHON MA SAN was blocked by the United States in February 2018, and subsequently it was listed by the UN in March 2018 for its involvement in a UN-prohibited ship-to-ship transfer in mid-November 2017. 

The following vessels have also been identified by OFAC as property in which Gudzon has an interest:

  • Russia-flagged vessel NEPTUN (IMO 8404991)
  • Russia-flagged vessel BELLA (IMO 8808264)
  • Russia-flagged vessel BOGATYR (IMO 9085730)
  • Russia-flagged vessel PARTIZAN (IMO 9113020)
  • Russia-flagged vessel SEVASTOPOL (IMO 9235127

Links:

OFAC Notice

Treasury North Korea Designations Press Release

Treasury Cyber-related Designations Press Release

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