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OFAC did not leave early for its weekend…

As you may have noticed, I try not to post after 5 PM Eastern time – people need to separate work from their personal lives, and I do this more in consideration of my readers than I do for myself (I do the Daily Digest of the day, as well as catch-up work in the evenings and on weekends, like I’m doing now – but I set the posting time for the “normal” US work day).

There are consequences for this choice – like OFAC’s 4:43 PM email announcing these changes. Yes, Treasury’s press releases were released a tad earlier – and I still have nothing in my inbox for State’s 3 releases. But, here we are…with late Friday changes for the Russia & North Korean situations…

Because there are so many pieces, I am going to do this in multiple parts…this one will be purely OFAC (although I am supplying all the other links here, too).

We had a new Executive Order from the President on Friday – here’s the guts of it:

Section 1. (a) The following are prohibited:

(i) the importation into the United States of the following products of Russian Federation origin: fish, seafood, and preparations thereof; alcoholic beverages; non-industrial diamonds; and any other products of Russian Federation origin as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State and the Secretary of Commerce;

(ii) the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, ofluxury goods, and any other items as may be determined by the Secretary of Commerce, in consultation with the Secretary of State and the Secretary of the Treasury, to any person located in the Russian Federation;

(iii) new investment in any sector of the Russian Federation economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, by a United States person, wherever located;

(iv) the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of U.S. dollar-denominated banknotes to the Government of the Russian Federation or any person located in the Russian Federation; and

(v) any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited by this section if performed by a United States person or within the United States.

And:

Sec.3. Nothing in this order shall prohibit transactions for the conduct of the official business of the Federal Government or the United Nations (including its specialized agencies, programs, funds, and related organizations) by employees, grantees, or contractors thereof.

And there are 4 General Licenses – Russia-related 17 (existing import agreements for Russian fish, seafood, alcohol, non-industrial diamonds), 18 (US Banknote noncommercial personal remittances), 19 (personal maintenance of US persons located in Russia) and Ukraine-related 23 (NGO activities).

And there are designations – persons:

AFONIN, Yuriy Vyacheslavovich (Cyrillic: АФОНИН, Юрий Вячеславович) (a.k.a. AFONIN, Yuri Vyacheslavovich; a.k.a. AFONIN, Yuri Vyacheslavovich; a.k.a. AFONIN, Yury Vyacheslavovich), Russia; DOB 22 Mar 1977; POB Tula, Russia; nationality Russia; Gender Male; Member of the State Duma of the Federal Assembly of the Russian Federation (individual) [RUSSIA-EO14024]. 

ANDRESOV, Yuriy Nikolaevich (Cyrillic: АНДРЕСОВ, Юрий Николаевич), Russia; DOB 1969; POB Bashkortostan, Russia; nationality Russia; Gender Male (individual) [RUSSIA-EO14024].

BELOUS, German Valentinovich (Cyrillic: БЕЛОУС, Герман Валентинович) (a.k.a. BELOUS, German (Cyrillic: БЕЛОУС, Герман)), 12-2 Chistoprudny Boul, Apt 79, Moscow 101000, Russia; DOB 14 Nov 1977; POB Klin, Russia; nationality Russia; Gender Male; Passport 718489066 (Russia); National ID No. 4514863944 (Russia) (individual) [RUSSIA-EO14024].

BESSONOV, Yevgeniy Ivanovich (Cyrillic: БЕССОНОВ, Евгений Иванович) (a.k.a. BESSONOV, Evgeny Ivanovich), Russia; DOB 26 Nov 1968; POB Rostov-Na-Donu, Russia; nationality Russia; Gender Male; Member of the State Duma of the Federal Assembly of the Russian (individual) [RUSSIA-EO14024].

DERGUNOVA, Olga Konstantinovna (Cyrillic: ДЕРГУНОВА, Ольга Константиновна) (a.k.a. DERGUNOVA, Olga), Russia; DOB 15 May 1965; POB Moscow, Russia; nationality Russia; Gender Female; Tax ID No. 1802787483 (Russia) (individual) [RUSSIA-EO14024].

DIRKS, Natalia Germanova (Cyrillic: ДИРКС, Наталья Германовна) (a.k.a. DIRKS, Natalya Germanovna), Russia; DOB 17 Sep 1961; nationality Russia; Gender Female (individual) [RUSSIA-EO14024].

GEORGIEVA, Elena Aleksandrovna (Cyrillic: ГЕОРГИЕВА, Елена Александровна), Moscow, Russia; DOB 15 Feb 1977; POB Moscow, Russia; nationality Russia; Gender Female; Tax ID No. 771988299175 (Russia) (individual) [RUSSIA-EO14024].

KALASHNIKOV, Leonid Ivanovich (Cyrillic: КАЛАШНИКОВ, Леонид Иванович), Russia; DOB 06 Aug 1960; POB Stepnoy Dvorets, Russia; nationality Russia; Gender Male; Member of the State Duma of the Federal Assembly of the Russian Federation (individual) [RUSSIA-EO14024].

KASHIN, Vladimir Ivanovich (Cyrillic: КАШИН, Владимир Иванович), Russia; DOB 10 Aug 1948; POB Nazarevo, Ryazan Region, Russia; nationality Russia; Gender Male; Member of the State Duma of the Federal Assembly of the Russian Federation (individual) [RUSSIA-EO14024].

KNYAGININ, Vladimir Nikolaevich (Cyrillic: КНЯГИНИН, Владимир Николаевич) (a.k.a. KNIAGININ, Vladimir Nikolaevich; a.k.a. KNIAGININ, Vladimir Nikolayevich; a.k.a. KNYAGININ, Vladimir Nikolayevich), Russia; DOB 20 Jan 1961; POB Abakan, Khakasia Republic, Russia; nationality Russia; Gender Male (individual) [RUSSIA-EO14024] (Linked To: AO ABR MANAGEMENT).

KOLOMEITSEV, Nikolay Vasilievich (Cyrillic: КОЛОМЕЙЦЕВ, Николай Васильевич) (a.k.a. KOLOMEITSEV, Nikolai Vasilyevich; a.k.a. KOLOMEYTSEV, Nikolay Vasilyevich), Russia; DOB 01 Sep 1956; POB Rostov Region, Russia; nationality Russia; Gender Male; Member of the State Duma of the Federal Assembly of the Russian Federation (individual) [RUSSIA-EO14024].

KONDRATENKO, Maxim Dmitrievich, Russia; DOB 31 Jul 1973; nationality Russia; Gender Male (individual) [RUSSIA-EO14024].

KOVALCHUK, Boris Yurievich (Cyrillic: КОВАЛЬЧУК, Борис Юрьевич), Russia; DOB 01 Dec 1977; POB St. Petersburg, Russia; nationality Russia; Gender Male; Tax ID No. 780150854932 (Russia) (individual) [RUSSIA-EO14024] (Linked To: KOVALCHUK, Yuri Valentinovich).

KOVALCHUK, Kira Valentinovna (Cyrillic: КОВАЛЬЧУК, Кира Валентиновна), Moscow, Russia; DOB 18 May 1971; POB Russia; nationality Russia; Gender Female; Passport 643267033 (Russia); Tax ID No. 770305521971 (Russia) (individual) [RUSSIA-EO14024] (Linked To: KOVALCHUK, Kirill Mikhailovich).

KOVALCHUK, Stepan Kirillovich (Cyrillic: КОВАЛЬЧУК, Степан Кириллович), Moscow, Russia; DOB 03 May 1994; POB Russia; nationality Russia; Gender Male; Passport 644557612 (Russia) (individual) [RUSSIA-EO14024] (Linked To: KOVALCHUK, Kirill Mikhailovich).

KOVALCHUK, Tatyana Aleksandrovna (Cyrillic: КОВАЛЬЧУК, Татьяна Александровна) (a.k.a. KOVALCHUK, Tatiana Aleksandrovna; a.k.a. KOVALCHUK, Tatyana Alexandrovna), Russia; DOB 08 Feb 1968; POB Russia; nationality Russia; Gender Female; Passport 51N0128733 (Russia); Tax ID No. 780150859761 (Russia) (individual) [RUSSIA-EO14024] (Linked To: KOVALCHUK, Yuri Valentinovich).

KULIK, Vadim Valerievich (Cyrillic: КУЛИК, Вадим Валерьевич) (a.k.a. KULIK, Vadim), Russia; DOB 14 Aug 1972; POB Nalchik, Russia; nationality Russia; Gender Male (individual) [RUSSIA-EO14024].

KURINNIY, Aleksey Vladimirovich (Cyrillic: КУРИННЫЙ, Алексей Владимирович) (a.k.a. KURINNY, Alexey Vladimirovich), Russia; DOB 18 Jan 1974; nationality Russia; Gender Male; Member of the State Duma of the Federal Assembly of the Russian Federation (individual) [RUSSIA-EO14024].

LUKYANENKO, Valerii Vasilyevich (Cyrillic: ЛУКЬЯНЕНКО, Валерий Васильевич) (a.k.a. LUKYANENKO, Valery), Russia; DOB 1955; POB Novosibirsk Oblast, Russia; nationality Russia; Gender Male (individual) [RUSSIA-EO14024].

MELNIKOV, Ivan Ivanovich (Cyrillic: МЕЛЬНИКОВ, Иван Иванович), Russia; DOB 07 Aug 1950; POB Bogoroditsk, Russia; nationality Russia; Gender Male; Member of the State Duma of the Federal Assembly of the Russian Federation (individual) [RUSSIA-EO14024].

NAVKA, Tatiana Aleksandrovna (a.k.a. NAVKA, Tatyana), 13-3-22 Bolshaya Yakimanka, Moscow 119180, Russia; Polyanka, Russia; Tretya Okhota, Russia; Rublyovka, Russia; Yalta, Crimea, Ukraine; DOB 13 Apr 1975; POB Dnipropetrovsk, Ukraine; nationality Russia; Gender Female (individual) [RUSSIA-EO14024] (Linked To: PESKOV, Dmitriy Sergeevich).

NOROV, Erkin Rakhmatovich (Cyrillic: НОРОВ, Эркин Рахматович), Russia; DOB 1954; POB Moscow, Russia; nationality Russia; Gender Male (individual) [RUSSIA-EO14024].

NOVIKOV, Dmitriy Georgievich (Cyrillic: НОВИКОВ, Дмитрий Георгиевич) (a.k.a. NOVIKOV, Dmitry Georgievich), Russia; DOB 12 Sep 1969; nationality Russia; Gender Male; Member of the State Duma of the Federal Assembly of the Russian Federation (individual) [RUSSIA-EO14024].

OSADCHIY, Nikolay Ivanovich (Cyrillic: ОСАДЧИЙ, Николай Иванович) (a.k.a. OSADCHII, Nikolay; a.k.a. OSADCHY, Nikolay Ivanovich), Russia; DOB 08 Dec 1957; POB Tuapse, Russia; nationality Russia; Gender Male; Member of the State Duma of the Federal Assembly of the Russian Federation (individual) [RUSSIA-EO14024].

OSTROVSKY, Svyatoslav Evgenievich (Cyrillic: ОСТРОВСКИЙ, Святослав Евгеньевич) (a.k.a. OSTROVSKIY, Svyatoslav Yevgenievich), Russia; DOB 09 Mar 1979; POB Krasnodar Region, Russia; nationality Russia; Gender Male (individual) [RUSSIA-EO14024].

PECHATNIKOV, Anatolii Yuryevich (Cyrillic: ПЕЧАТНИКОВ, Анатолий Юрьевич) (a.k.a. PECHATNIKOV, Anatoly), Russia; DOB 18 Aug 1969; POB Moscow, Russia; nationality Russia; Gender Male (individual) [RUSSIA-EO14024].

PESKOV, Nikolay (a.k.a. CHOLES, Nikolai; a.k.a. CHOULZ, Nikolay Dmitrievich; a.k.a. CHOULZ, Nikolay Dmitriyevich), B. Dorogomilovskaia, 7 81, Moscow 127473, Russia; DOB 03 Feb 1990; POB Moscow, Russia; nationality Russia; Gender Male; Passport 721123760 (Russia) issued 12 Sep 2012 expires 12 Sep 2022; National ID No. 4516913332 (Russia) (individual) [RUSSIA-EO14024] (Linked To: PESKOV, Dmitriy Sergeevich).

PESKOVA, Elizaveta Dmitriyevna (a.k.a. PESKOV, Liza; a.k.a. PESKOVA, Elizaveta Dmitrievna; a.k.a. PESKOVA, Liza; a.k.a. PESKOVA, Yelizaveta), Moscow, Russia; Paris, France; Brussels, Belgium; DOB 09 Jan 1998; POB Ankara, Turkey; nationality Russia; Gender Female (individual) [RUSSIA-EO14024] (Linked To: PESKOV, Dmitriy Sergeevich).

PYANOV, Dmitrii Vasilyevich (Cyrillic: ПЬЯНОВ, Дмитрий Васильевич) (a.k.a. PYANOV, Dmitrii Vasilevich), Russia; DOB 07 Dec 1977; nationality Russia; Gender Male (individual) [RUSSIA-EO14024].

SAPELIN, Andrey Yurievich (Cyrillic: САПЕЛИН, Андрей Юрьевич), Chertanovskaya Street 1B-1-289, Moscow 117639, Russia; DOB 16 Sep 1965; POB Belgorod, Russia; nationality Russia; Gender Male; Passport 530186647 (Russia); Tax ID No. 772616582963 (Russia) (individual) [RUSSIA-EO14024].

TAYSAEV, Kazbek Kutsukovich (a.k.a. TAISAEV, Kazbek Kutsukovich; a.k.a. TAISAYEV, Kazbek), Russia; DOB 12 Feb 1967; POB Chikola, North Ossetia, Russia; nationality Russia; Gender Male; Member of the State Duma of the Federal Assembly of the Russian Federation (individual) [RUSSIA-EO14024].

VAVULIN, Dmitri Nikolaevich (Cyrillic: ВАВУЛИН, Дмитрий Николаевич), Moscow, Russia; DOB 1969; nationality Russia; Gender Male (individual) [RUSSIA-EO14024].

ZYUGANOV, Gennady Andreyevich (a.k.a. ZYUGANOV, Gennadiy Andreevich), Russia; DOB 26 Jun 1944; POB Mymrino, Oryol, Russia; nationality Russia; Gender Male; Member of the State Duma of the Federal Assembly of the Russian Federation (individual) [RUSSIA-EO14024].

vessels:

TANGO (E5U3540) Yacht 2,083GRT Cook Islands flag; Vessel Registration Identification IMO 1010703; MMSI 518100626 (vessel) [RUSSIA-EO14024] (Linked To: VEKSELBERG, Viktor Feliksovich). 

and aircraft:

P4-MIS; Aircraft Manufacture Date 31 May 2007; Aircraft Model Airbus A319-115; Aircraft Manufacturer's Serial Number (MSN) 3133; Aircraft Tail Number P4-MIS (aircraft) [RUSSIA-EO14024] (Linked To: VEKSELBERG, Viktor Feliksovich). 

under the Russian Harmful Foreign Activities program, and persons:

CHASOVNIKOV, Aleksandr Aleksandrovich, Vladivostok, Russia; DOB 09 May 1969; nationality Russia; Gender Male; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214 (individual) [DPRK2]. 

GAYEVOY, Aleksandr Andreyevich (a.k.a. GAEVOI, Aleksandr Andreevich; a.k.a. GAEVOY, Aleksandr), Vladivostok, Russia; DOB 16 Jun 1986; POB Artem, Primorkiy Kray, Russia; nationality Russia; Gender Male; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214 (individual) [DPRK2] (Linked To: APOLLON OOO).

and entities:

APOLLON OOO (a.k.a. APOLLON LLC; a.k.a. "APOLLON"), Ul. Semenovskaya D., 8B, Kv. 28, Vladivostok 690091, Russia; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214; Organization Established Date 29 Jun 2015; Organization Type: Wholesale of food, beverages and tobacco; Tax ID No. 2540211930 (Russia); Registration Number 1152540004253 (Russia) [DPRK2] (Linked To: PAK, Kwang Hun). 

RK BRIZ, OOO (a.k.a. RK BREEZE; a.k.a. RK BRIZ; a.k.a. RK BRIZ LLC), Ul. Partizanskaya D. 2, Pom. 1, Putyatin 692815, Russia; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214; Organization Established Date 18 Jul 2016; Organization Type: Processing and preserving of fish, crustaceans and molluscs; Tax ID No. 2503033077 (Russia); Government Gazette Number 03561816 (Russia); Registration Number 1162503050654 (Russia) [DPRK2] (Linked To: CHASOVNIKOV, Aleksandr Aleksandrovich).

ZEEL - M CO., LTD. (a.k.a. ZIL-M LLC; a.k.a. "ZEELM"; a.k.a. "ZIL - M"), Ul. Russkaya D. 19, V, Vladivostok 690039, Russia; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214; Organization Established Date 08 Dec 1998; Organization Type: Sale of motor vehicles; Tax ID No. 2539039058 (Russia); Government Gazette Number 49852298 (Russia); Registration Number 1022502123995 (Russia) [DPRK2] (Linked To: CHASOVNIKOV, Aleksandr Aleksandrovich).

under the North Korea program. There are also updates:

CJSC ABR MANAGEMENT (a.k.a. ABR MANAGEMENT CJSC; a.k.a. ZAKRYTOE AKTSIONERNOE OBSHCHESTVO ABR MANAGEMENT; a.k.a. "ABR"), 2 Liter A, Rastrelli Sq, St. Petersburg 191124, Russia; Ulitsa Graftio, Dom 7, Liter A, St. Petersburg 197022, Russia [UKRAINE-EO13661] (Linked To: BANK ROSSIYA). -to- AO ABR MANAGEMENT (Cyrillic: АО АБР МЕНЕДЖМЕНТ) (a.k.a. ABR MANAGEMENT AO (Cyrillic: АБР МЕНЕДЖМЕНТ АО); a.k.a. AKTSIONERNOE OBSHCHESTVO ABR MENEDZHMENT; a.k.a. AO ABR MENEDZHMENT; a.k.a. JOINT STOCK COMPANY ABR MANAGEMENT; a.k.a. "ABR MANAGEMENT"), ul. Graftio, d. 7 litera A, g. Sankt-Peterburg 197022, Russia; Tax ID No. 7842467053 (Russia); Registration Number 1117847707383 (Russia) [UKRAINE-EO13661] [RUSSIA-EO14024] (Linked To: BANK ROSSIYA). 

KOVALCHUK, Kirill Mikhailovich, Russia; DOB 1968; Gender Male (individual) [UKRAINE-EO13661]. -to- KOVALCHUK, Kirill Mikhailovich (Cyrillic: КОВАЛЬЧУК, Кирилл Михайлович) (a.k.a. KOVALCHUK, Kyrylo Mykhailovych; a.k.a. KOVALCHUK, Kyrylo Mykhaylovych (Cyrillic: КОВАЛЬЧУК, Кирило Михайлович)), Moscow, Russia; DOB 22 Dec 1968; POB Moscow, Russia; alt. POB St. Petersburg, Russia; nationality Russia; Gender Male; Passport 643267034 (Russia); Tax ID No. 773600308808 (Russia) (individual) [UKRAINE-EO13661] [RUSSIA-EO14024] (Linked To: AO ABR MANAGEMENT).

KOVALCHUK, Yuri Valentinovich (a.k.a. KOVALCHUK, Yury Valentinovich); DOB 25 Jul 1951; POB Saint Petersburg, Russia (individual) [UKRAINE-EO13661]. -to- KOVALCHUK, Yuri Valentinovich (Cyrillic: КОВАЛЧУК, Юрий Валентинович) (a.k.a. KOVALCHUK, Yuriy Valentynovych (Cyrillic: КОВАЛЬЧУК, Юрій Валентинович); a.k.a. KOVALCHUK, Yury Valentinovich), Russia; DOB 25 Jul 1951; POB St. Petersburg, Russia; nationality Russia; Gender Male; Tax ID No. 780105029790 (Russia) (individual) [UKRAINE-EO13661] [RUSSIA-EO14024] (Linked To: AO ABR MANAGEMENT).

LEBEDEV, Dmitri Alekseevich, Russia; DOB 1968; Gender Male (individual) [UKRAINE-EO13661]. -to- LEBEDEV, Dmitri Alekseevich (Cyrillic: ЛЕБЕДЕВ, Дмитрий Алексеевич), Russia; DOB 30 Mar 1968; POB St. Petersburg, Russia; nationality Russia; Gender Male (individual) [UKRAINE-EO13661] [RUSSIA-EO14024] (Linked To: AO ABR MANAGEMENT).

VEKSELBERG, Viktor Feliksovich, Russia; DOB 14 Apr 1957; POB Drogobych, Lviv region, Ukraine; Gender Male (individual) [UKRAINE-EO13662]. -to- VEKSELBERG, Viktor Feliksovich (Cyrillic: ВЕКСЕЛЬБЕРГ, Виктор Феликсович) (a.k.a. VEKSELBERG, Victor (Cyrillic: ВЕКСЕЛЬБЕРГ, Виктор)), Russia; DOB 14 Apr 1957; POB Drogobych, Lviv region, Ukraine; Gender Male (individual) [UKRAINE-EO13662] [RUSSIA-EO14024].

VOLODIN, Vyacheslav; DOB 04 Feb 1964; POB Alexeyevka, Khvalynsk district, Saratov, Russia; First Deputy Chief of Staff of the Presidential Executive Office (individual) [UKRAINE-EO13661]. -to- VOLODIN, Vyacheslav Victorovich (Cyrillic: ВОЛОДИН, Вячеслав Викторович), Russia; DOB 04 Feb 1964; POB Alexeevka, Saratov, Russia; nationality Russia; Gender Male; Speaker of the State Duma of the Federal Assembly of the Russian Federation; Member of Russian Security Council (individual) [UKRAINE-EO13661] [RUSSIA-EO14024].

which add designations under the Russian Harmful Foreign Activities program to existing designations under a number of Ukraine-related Executive Orders, and updates to current Russia and Belarus listings (one each):

DMITRY, Pantus Aleksandrovich (a.k.a. PANTUS, Dmitriy (Cyrillic: ПАНТУС, Дмитрий); a.k.a. PANTUS, Dzmitry), Minsk, Belarus; DOB 06 Sep 1982; POB Beryozovka, Lida District, Grodno Region, Belarus; nationality Belarus; Gender Male (individual) [BELARUS-EO14038]. -to- PANTUS, Dmitry Aleksandrovich (a.k.a. PANTUS, Dmitriy (Cyrillic: ПАНТУС, Дмитрий); a.k.a. PANTUS, Dzmitry), Minsk, Belarus; DOB 06 Sep 1982; POB Beryozovka, Lida District, Grodno Region, Belarus; nationality Belarus; Gender Male (individual) [BELARUS-EO14038]. 

JOINT STOCK COMPANY MANAGEMENT COMPANY OF THE RUSSIAN DIRECT INVESTMENT FUND (Cyrillic: АКЦИОНЕРНОЕ ОБЩЕСТВО УПРАВЛЯЮЩАЯ КОМПАНИЯ РОССИЙСКОГО ФОНДА ПРЯМЫХ ИНВЕСТИЦИЙ) (a.k.a. AKTSIONERNOE OBSHCHESTVO UPRAVLYAYUSHCHAYA KOMPANIYA ROSSISKOGO FONDA PRYAMYKH INVESTITSI; a.k.a. AKTSIONERNOYE OBSHCHESTVO UPRAVLYAYUSHCHAYA KOMPANIYA ROSSIYSKOGO FONDA PRYAMYKH INVESTITSIY; f.k.a. LIMITED LIABILITY COMPANY MANAGEMENT COMPANY OF RDIF; f.k.a. OBSHCHESTVO S OGRANICHENNOY OTVETSTVENNOSTYU UPRAVLYAYUSHCHAYA KOMPANIYA RFPI (Cyrillic: ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ); a.k.a. "AO UK RFPI" (Cyrillic: "АО УК РФПИ"); a.k.a. "JSC MC RDIF"), Naberezhnaya Presnenskaya, Dom 8 Stroyeniye 1, Etaj 7, Moscow 123112, Russia (Cyrillic: Набережная Пресненская, Дом 8, Строение 1, Этаж 7, Москва 123112, Russia); Website www.rdif.ru; alt. Website www.investinrussia.com; Organization Established Date 11 Apr 2017; Organization Type: Trusts, funds and similar financial entities; Target Type Financial Institution; alt. Target Type State-Owned Enterprise; Tax ID No. 7703425673 (Russia); Government Gazette Number 15110384 (Russia); Registration Number 1177746367017 (Russia) [RUSSIA-EO14024]. -to- JOINT STOCK COMPANY MANAGEMENT COMPANY OF THE RUSSIAN DIRECT INVESTMENT FUND (Cyrillic: АКЦИОНЕРНОЕ ОБЩЕСТВО УПРАВЛЯЮЩАЯ КОМПАНИЯ РОССИЙСКОГО ФОНДА ПРЯМЫХ ИНВЕСТИЦИЙ) (a.k.a. AKTSIONERNOE OBSHCHESTVO UPRAVLYAYUSHCHAYA KOMPANIYA ROSSISKOGO FONDA PRYAMYKH INVESTITSI; a.k.a. AKTSIONERNOYE OBSHCHESTVO UPRAVLYAYUSHCHAYA KOMPANIYA ROSSIYSKOGO FONDA PRYAMYKH INVESTITSIY; f.k.a. LIMITED LIABILITY COMPANY MANAGEMENT COMPANY OF RDIF; f.k.a. OBSHCHESTVO S OGRANICHENNOY OTVETSTVENNOSTYU UPRAVLYAYUSHCHAYA KOMPANIYA RFPI (Cyrillic: ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ УПРАВЛЯЮЩАЯ КОМПАНИЯ РФПИ); a.k.a. "AO UK RFPI" (Cyrillic: "АО УК РФПИ"); a.k.a. "JSC MC RDIF"), Naberezhnaya Presnenskaya, Dom 8 Stroyeniye 1, Etaj 7, Moscow 123112, Russia (Cyrillic: Набережная Пресненская, Дом 8, Строение 1, Этаж 7, Москва 123112, Russia); Website www.rdif.ru; alt. Website www.investinrussia.com; Organization Established Date 11 Apr 2017; Organization Type: Trusts, funds and similar financial entities; Target Type Financial Institution; alt. Target Type State-Owned Enterprise; Tax ID No. 7703425673 (Russia); Government Gazette Number 15110384 (Russia); Registration Number 1177746367017 (Russia) [RUSSIA-EO14024].

And there are new:

Russian Harmful Foreign Activities Sanctions

1,028. Does the U.S. dollar-denominated banknote export ban imposed by Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” prohibit sending noncommercial, personal remittances denominated in U.S. dollars to the Russia Federation (or to individuals ordinarily resident in the Russia Federation)?

E.O. of March 11, 2022 prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of U.S. dollar-denominated banknotes to the Government of the Russian Federation or any person located in the Russian Federation.  However, Russia-related General License (GL) 18 authorizes certain transactions that are ordinarily incident and necessary to the transfer of U.S. dollar-denominated banknotes for noncommercial, personal remittances from:  (i) the United States or a U.S. person, wherever located, to an individual located in the Russian Federation; or (ii) a U.S. person who is an individual located in the Russian Federation.

GL 18 authorizes methods of payment including withdrawals of U.S. dollar-denominated banknotes via automated teller machines and the hand carrying of U.S. dollar-denominated banknotes. 

Note that GL 18 does not authorize U.S. financial institutions to process transactions for the provision of U.S. dollar-denominated banknotes to foreign financial institutions for further distribution or supply to the Government of the Russian Federation or any person located in the Russian Federation.
 

Released on 03/11/2022

Russian Harmful Foreign Activities Sanctions

1,027. For the purposes of Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” what is meant by the terms “Russian Federation origin,” “fish, seafood, and preparations thereof,” “alcoholic beverages,” and “non-industrial diamonds”?

For the purposes of E.O. of March 11, 2022, the Office of Foreign Assets Control anticipates publishing regulations defining these terms to include the following:

  • “Russian Federation origin” – see FAQ 1,019.
  • “fish, seafood, and preparations thereof” – articles defined at Harmonized Tariff Schedule of the United States (HTSUS) subheadings 0301.11.00 to 0301.99.03; 0302.11.00 to 0302.99.00; 0303.11.00 to 0303.99.00; 0304.31.00 to 0304.99.91; 0305.20.20 to 0305.79.00; 0306.11.00 to 0306.99.01; 0307.11.00 to 0307.99.03; 0308.11.00 to 0308.90.01; 0309.10.05 to 0309.90.90; 1603.00.10; 1603.00.90; 1604.11.20 to 1604.32.40; 1605.10.05 to 1605.69.00; 0508.00.0000; 2301.20.0010; 2310.20.0090; 1504.10.20 to 1504.20.60; and 2106.90.9998, including any subsequent revisions to the list of HTSUS classifications.
  • “alcoholic beverages” – articles defined at HTSUS subheadings 2203.00.00; 2204.10.00 to 2204.30.00; 2205.10.30 to 2205.90.60; 2206.00.15 to 2206.00.90; 2207.10.30 to 2207.20.00; and 2208.20.10 to 2208.90.80, including any subsequent revisions to the list of HTSUS classifications.
  • “non-industrial diamonds” – articles defined at HTSUS subheadings 7102.31.00 and 7102.39.00, including any subsequent revisions to the list of HTSUS classifications.

With respect to the export prohibitions set forth in section 1(a)(ii) of E.O. of March 11, 2022, please consult the U.S. Department of Commerce, Bureau of Industry and Security, for guidance.

Released on 03/11/2022

Russian Harmful Foreign Activities Sanctions

1,026. Are non-U.S. persons exposed to sanctions if they continue to import to non-U.S. jurisdictions certain products of Russian Federation origin that are banned from the United States pursuant to Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression”?

E.O. of March 11, 2022 prohibits the importation into the United States of fish, seafood, and preparations thereof; alcoholic beverages; and non-industrial diamonds of Russian Federation origin.  To the extent the import of such products of Russian Federation origin to jurisdictions outside of the United States does not involve a sanctioned person or an otherwise prohibited transaction, non-U.S. persons are not exposed to sanctions under E.O. of March 11, 2022.

Released on 03/11/2022

Russian Harmful Foreign Activities Sanctions

1,025. Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression” prohibits the importation into the United States of fish, seafood, and preparations thereof of Russian Federation origin.  How does this affect Russia-related General License (GL) 6?

Russia-related GL 6 (“Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, or the Coronavirus Disease 2019 (COVID-19) Pandemic”) remains valid and authorizes, among other things, transactions ordinarily incident and necessary to (1) the exportation or reexportation of agricultural commodities, including products such as fish, seafood, or preparations thereof — to the extent they fall within the definition of agricultural commodities provided in GL 6 — to, from, or transiting the Russian Federation (see FAQ 979).  However, GL 6 does not authorize any transactions prohibited by E.O. of March 11, 2022.  As such, U.S. persons can continue to rely on GL 6 for transactions otherwise prohibited by E.O. 14024 involving agricultural commodities, such as fish, seafood, and preparations thereof, provided such transactions are not for the importation of these Russian origin products into the United States, unless otherwise authorized by OFAC.

Released on 03/11/2022

Russian Harmful Foreign Activities Sanctions

1,024. I have a shipment of a certain product(s) listed in Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” en route to the United States that were contracted prior to March 11, 2022.  Can I find a new buyer for this shipment, re-direct the shipment to a country other than the United States, or import the product(s) and comply with the import ban?

Yes.  E.O. of March 11, 2022 prohibits the importation into the United States of fish, seafood, and preparations thereof; alcoholic beverages; and non-industrial diamonds of Russian Federation origin.  It does not prohibit U.S. persons from engaging in transactions to sell or re-direct shipments outside the United States that were previously destined for the United States.

In addition, the Office of Foreign of Assets Control (OFAC) has also issued Russia-related General License (GL) 17 to authorize the import, for a limited time, of certain items pursuant to pre-existing written contracts or written agreements (see FAQ 1023).  GL 17 provides such authorization for importing fish, seafood, and preparations thereof; alcoholic beverages; or non-industrial diamonds of Russian Federation origin through March 25, 2022.  OFAC may issue specific licenses on a case-by-case basis to authorize shipments occurring after the expiry of GL 17 or for other activity outside the scope of this GL.

Released on 03/11/2022

Russian Harmful Foreign Activities Sanctions

1,023. Is there a period of time for U.S. persons to continue importing products prohibited by Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression”?

Russia-related General License (GL) 17 authorizes through March 25, 2022 transactions that are ordinarily incident and necessary to the importation into the United States of fish, seafood, and preparations thereof; alcoholic beverages; or non-industrial diamonds of Russian Federation origin pursuant to written contracts or written agreements entered into prior to March 11, 2022.  GL 17 does not authorize entry into new contracts.

Additionally, E.O. of March 11, 2022 does not prohibit transactions such as the unwinding of contracts or other business-related activities by U.S. persons to comply with the import ban imposed under E.O. of March 11, 2022.  Likewise, E.O. of March 11, 2022 does not prohibit U.S. persons from engaging in transactions to sell or re-direct shipments outside the United States of prohibited imports previously destined for the United States.

Note that other prohibitions specified in E.O. of March 11, 2022 are effective immediately.  Additionally, with respect to the export prohibitions set forth in section 1(a)(ii) of E.O. of March 11, 2022, please consult the U.S. Department of Commerce, Bureau of Industry and Security, for guidance.

Released on 03/11/2022

Russian Harmful Foreign Activities Sanctions

1,022. What does Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” do?

E.O. of March 11, 2022 prohibits the following activities:

  • the importation into the United States of the following products of Russian Federation origin:  fish, seafood, and preparations thereof; alcoholic beverages; non-industrial diamonds; and any other products of Russian Federation origin as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State and the Secretary of Commerce;
  • the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of luxury goods, and any other items as may be determined by the Secretary of Commerce, in consultation with the Secretary of State and the Secretary of the Treasury, to any person located in the Russian Federation;
  • new investment in any sector of the Russian Federation economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, by a United States person, wherever located;
  • the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of U.S. dollar-denominated banknotes to the Government of the Russian Federation or any person located in the Russian Federation; and
  • any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited by sections 1(a)(i)-(iv) of E.O. of March 11, 2022 if performed by a United States person or within the United States.

Released on 03/11/2022

Russian Harmful Foreign Activities Sanctions

1,021. Do the prohibitions of Executive Order (E.O.) 14024 and other Russia-related sanctions extend to virtual currency? 

Yes.  The Office of Foreign Assets Control (OFAC) has imposed expansive sanctions actions against certain Russian entities and individuals pursuant to E.O. 14024, in addition to other authorities.  All U.S. persons are required to comply with OFAC regulations, regardless of whether a transaction is denominated in traditional fiat currency or virtual currency (see FAQ 560).

Sanctioned Russian persons are known to employ a wide variety of measures in their efforts to evade U.S. and international sanctions.  As such, U.S. persons, wherever located, including firms that process virtual currency transactions, must be vigilant against attempts to circumvent OFAC regulations and must take risk-based steps to ensure they do not engage in prohibited transactions.  For additional information regarding sanctions compliance best practices for the virtual currency industry, please see OFAC’s Sanctions Compliance Guidance for the Virtual Currency Industry.

U.S. persons, including virtual currency exchanges, virtual wallet hosts, and other service providers, such as those that provide nested services for foreign exchanges, are generally prohibited from engaging in or facilitating prohibited transactions, including virtual currency transactions in which blocked persons have an interest.  U.S. persons are further prohibited from engaging in or facilitating any transaction by a non-U.S. person that would be prohibited if performed by a U.S. person or within the United States, including virtual currency transactions involving the Central Bank of the Russian Federation, National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.  Among other activities, U.S. financial institutions are also generally prohibited from processing transactions, including virtual currency transactions, involving foreign financial institutions that are determined to be subject to the prohibitions of Directive 2 under Executive Order 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions”.  For additional information regarding the Russia-related CAPTA Directive, please see FAQ 967.

Non-U.S. persons are also subject to certain OFAC prohibitions.  Such persons, for example, are prohibited from causing or conspiring to cause U.S. persons to violate U.S. sanctions, as well as engaging in conduct that evades or avoids a violation of OFAC sanctions.  Violations of OFAC regulations may result in criminal or civil penalties.

E.O. 14024 further authorizes sanctions against persons determined to be responsible for or complicit in, or to have directly or indirectly engaged or attempted to engage in, deceptive or structured transactions or dealings to circumvent U.S. sanctions, including through the use of digital currencies or assets, or the use of physical assets.  E.O. 14024 also authorizes sanctions against persons determined to operate or to have operated in the financial services or technology sectors of the Russian Federation economy, as well as persons that have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, blocked persons.

OFAC is closely monitoring any efforts to circumvent or violate Russia-related sanctions, including through the use of virtual currency, and is committed to using its broad enforcement authorities to act against violations and to promote compliance.

For additional information regarding the application of sanctions to virtual currency, please see FAQs 559560561562563594646647, and 971, as well as OFAC’s Sanctions Compliance Guidance for the Virtual Currency Industry.

For additional Treasury guidance on Russia and sanctions evasion, please see FinCEN’s Alert on Increased Vigilance for Potential Russian Sanctions Evasion Attempts.

Released on 03/11/2022

and updated:

Ukraine-/Russia-related Sanctions

1,007. Are U.S. persons authorized to engage in certain activity with the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions”)?

U.S. persons are authorized through a variety of Ukraine-related general licenses (GLs) to support certain humanitarian efforts and other activity in the Covered Regions, including transactions related to the export of food or medicine, the response to the Coronavirus Disease 2019 (COVID-19) pandemic, the official business of an international organization, or the activities of nongovernmental organizations, as well as personal remittances, telecommunications, internet services, and mail.

  • GL 18 authorizes certain transactions that are ordinarily incident and necessary to:  (1)  the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to the Covered Regions, or to persons in third countries purchasing specifically for resale to the Covered Regions; or (2) the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19).
  • GL 19 authorizes certain transactions related to telecommunications that are ordinarily incident and necessary to the receipt or transmission of telecommunications in the Covered Regions, as well as certain transactions of common carriers involving the Covered Regions that are ordinarily incident and necessary to the receipt or transmission of mail and packages.
  • GL 20 authorizes transactions for the conduct of the official business of certain international organizations and entities.  For an organizational chart of the United Nations, which lists the Programmes, Funds, and Other Entities and Bodies, as well as the Specialized Agencies and Related Organizations covered by GL 19, see the following page on the United Nations website: https://www.un.org/en/pdfs/un_system_chart.pdf.
  • GL 21 authorizes certain transactions that are ordinarily incident and necessary to the transfer of noncommercial, personal remittances to or from the Covered Regions or for or on behalf of an individual ordinarily resident in the Covered Regions.  Further, GL 21 authorizes certain transactions that are ordinarily incident and necessary to maintaining, operating, or closing an account of an individual ordinarily resident in the Covered Regions.  U.S. depository institutions, U.S.-registered brokers or dealers in securities, and U.S.-registered money transmitters are authorized to process noncommercial, personal remittances pursuant to GL 21 regardless of whether the originator or beneficiary is an individual who is a U.S. person.  GL 21 is not limited to a specific method of payment.
  • GL 22 authorizes certain transactions that are ordinarily incident and necessary to the exportation or reexportation, directly or indirectly, from the United States or by U.S. persons, wherever located, to persons in the Covered Regions, of services incident to the exchange of personal communications over the internet as well as the export of software to enable such services.  However, GL 22 does not authorize the exportation or reexportation, directly or indirectly, of services or software with knowledge or reason to know that such services or software are intended for any person whose property and interests in property are blocked. 
  • GL 23 authorizes certain transactions that are ordinarily incident and necessary to the support of nongovernmental organizations’ activities in the Covered Regions, including activities related humanitarian projects to meet basic human needs, democracy building, education, non-commercial developments projects, and environmental and natural resource protection.  Such transactions may include the processing and transfer of funds, payment of taxes, fees, and import duties, and purchase or receipt of permits, licenses, or public utility services

Date Updated: 03/11/2022

Updated on 03/11/2022

Frequently Asked Questions (FAQs).

There are also press releases from Treasury and State, and a Fact Sheet from State – I will post those separately.

Links:

OFAC Notice

Executive Order

Russia-related General Licenses – 17, 18. 19

Ukraine-related General License 23

FAQs – new, amended

Treasury Press Releases – Russia-related, DPRK-related

State Department Press Releases – Russia-related, DPRK-related

Russia-related Fact Sheet

Categories: Belarus Sanctions Frequently Asked Questions (FAQ) Licenses North Korea (DPRK) Sanctions OFAC Updates Russian Harmful Foreign Activities Sanctions Sanctions Lists Uncategorized

eric9to5

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