Russia, Ukraine: March 31 update

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The United States is targeting Russian sanctions dodgers in the latest round of nominations

On March 31, the US Treasury Department’s Office of Foreign Assets Control (OFAC) announced the designation of even more entities and individuals as it expands sanctions against Russia. These parties were referred to as Specially Designated Nationals (SDN); In general, US persons are prohibited from transacting with an SDN.

The designations cover several different Russian actors, including network and front companies involved in providing Western technology to the Russian defense sector, as follows:

  • OOO Serniya Engineering (Serniya) based in Moscow.
  • OOO Sertal (Sertal) based in Moscow.
  • OOO Robin Treid based in Russia (front company for Serniya).
  • K. based Majory LLP (front company for Serniya).
  • K. based Photon Pro LLP (front company for Serniya).
  • Spain-based Invention Bridge SL (acting for Serniya).
  • Singapore-based Alexsong Pte Ltd (supporting Serniya’s evasion of sanctions).

Individual company officials, executives also named

In addition to the companies, OFAC designated individuals to act on behalf of or as directors, officers, officers, or directors of the sanctioned companies:

  • Irina Viktorovna Nikolaeva (acting on behalf of Serniya).
  • Yevgeniya Aleksandrovna Podgornova (acting on behalf of Serniya).
  • Sergey Aleksandrovich Yershov (on behalf of Serniya).
  • Anton Alekseevich Krugovov (on behalf of Serniya and Senior Officer of Majory LLP).
  • Andrey Georgiyevich Zakharov (on behalf of Serniya).
  • Yevgeniy Aleksandrovich Grinin (on behalf of Serniya and Head of Photon Pro LLP).
  • Sergey Aleksandrovish Yershov (a leader of Serniya and acting on behalf of Sertal).
  • Viacheslav Yuryevich Dubrovinskiy (a leader of Serniya).
  • Tamara Aleksandrovna Topchi (a leader of Invention Bridge SL).

OFAC also blocked three companies owned or controlled by two of these individuals:

  • OOO Nauchno-Tekhnicheskii Tsentr Metrotek based in Russia (owned/controlled by Andrey Georgiyevich Zakharov).
  • OOO Pamkin Khaus based in Russia (owned/controlled by Andrey Georgiyevich Zakharov).
  • OOO Foton Pro based in Russia (owned/controlled by Yevgeniy Aleksandrovich Grinin).

Additional designations based on the entity’s role in acquiring dual-use products

OFAC appointed Evgeniya Vladimirovna Bernova and some of her companies operating in Europe along with a director of one of the companies for their role in acquiring dual-use devices on behalf of Russian end users:

  • Malta-based Malberg Ltd (Bernova’s company).
  • Nikita Alexsandrovich Sobolev (director of Malberg).
  • K. based Djeco Group LP (Bernova’s shell company).
  • The Malta-based Djeco Group Holding Ltd (Bernova’s shell company).
  • Maltarent Ltd. (Bernova’s letterbox company) based in Malta.
  • SCI Griber (Bernova’s shell company) based in France.
  • Moscow Sernia-Film Co. Ltd (Bernova acted as director).

Russian high-tech companies destined to enable war

OFAC designated the following communications and electronics companies to operate in Russia’s technology sector and support Russia’s war effort:

  • AO NII Vector, software and communications technology company (for providing the ability to track ships, aircraft and ground vehicles during the Russian invasion of Ukraine).
  • Joint Stock Company Mikron, Russia’s largest manufacturer/exporter of microelectronics (used to make chips for Mir, Russia’s national payment card system).
  • Molecular Electronics Research Institute, R&D institute (for research and design work for the government of Russia).

The Ministry of Finance expands the Russian sanctions authority

Also today, Treasury Secretary Yellen issued a provision under Executive Order (EO) 14024, extending sanctions to companies operating in Russia’s aerospace, shipping and/or electronics industries. Although sanctions against parties in these sectors have not yet been announced, the decision paves the way for such sanctions. This builds on the earlier provision related to the financial services sector of the Russian economy and the original power under EO 14024, which established the power to impose sanctions on parties in the technology and defense sectors of the Russian economy.

OFAC continues to identify Russian and other actors, even if they are not directly related to Ukraine

Although not directly related to the Russian invasion of Ukraine, OFAC also announced that it has accused employees of the State Research Center of the Central Scientific Research Institute of Chemistry and Mechanics (TsNIIKhM) of the Russian Federation for their role in the August 2017 cyberattack a middle appoints Petrochemical Plant East. These people are:

  • Evgeny Viktorovich Gladkikh, an employee of the TsNIIKhM Applied Development Center.
  • Servei Alekseevich Bobkov, Director General of TsNIIKhM.
  • Konstantin Vasilyevich Malevanyy, Deputy General Director of TsNIIKhM.

Also today, OFAC named Quantlog OY, a Finnish front company founded by Nikita Gennadievitch Kovalevskij, an individual named in September 2020 for involvement in the procurement of underwater diving equipment for the Russian Federal Security Service (FSB).

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