Treasury's Office of Foreign Asset Control designated dozens of entities as Washington continues to apply economic pressure on Moscow for it's invation of Ukraine.
The Juy 20 actions are intended
In a May 19, 2023 Supplemental Alert, Treasury’s Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) identified certain high priority items, primarily based on the Harmonized System (HS) code classification of components from Russian weapons systems recovered on the battlefield in Ukraine, to assist financial institutions in identifying suspicious transactions relating to possible export control evasion.
Items described by these HS codes have been found in multiple Russian weapons systems used against Ukraine. Many of the entities designated today have transferred certain of these high priority items to Russia-based end-users.
One of the most common tactics Russian entities have used to continue their importation of foreign-made electronics and technology is the use of third-party intermediaries and transshipment points outside of Russia.
Entities based in the Kyrgyz Republic have been frequent exporters of controlled electronics components and other technology to Russia since Russia began its full-scale invasion of Ukraine. Some of these shipments have subsequently supplied sensitive dual-use goods to entities in Russia’s defense sector.
LLC RM Design and Development (RMDD), established in March 2022, is a Kyrgyz Republic-based seller of electronic and telecommunication equipment and parts. Since its founding last year, RMDD has been a prolific shipper of dual-use goods to Russia, including to firms that have supplied electronics to Russia-based defense companies.
RMDD has sent hundreds of shipments of goods, including semiconductor devices, electronic integrated circuits, and capacitors to Russia-based companies
GTME Tekhnologii is a Kyrgyz Republic-based entity established in June 2022. GTME Tekhnologii has made dozens of shipments of goods to Russia, including high priority items included in the FinCEN-BIS Supplemental Alert, such as tantalum capacitors and electronic integrated circuits. GTME Tekhnologii’s primary customer has been Russia-based Technologies Systems and Complexes Limited(TSC), a vendor of electronic and digital equipment.
OSOO Kargolayn founded in March 2022, is a Kyrgyz Republic-based entity that has shipped millions of dollars of foreign-made aviation equipment to Russia, including directly to airlines that are subject to U.S. export controls.
Amegino FZE a UAE-based engineering and services company that provides electronic components and related industry services.
AK Microtech (AKM) is a Russia-based firm that specializes in transferring foreign semiconductor technology to Russian microelectronics production companies. AKM uses non-Russian intermediaries to obfuscate Russian recipients, including Serbian firm MCI Trading DOO Beograd Palilula, which has helped AKM acquire high-tech items from producers in Asia, Europe, and the Middle East.
OFAC continues to target Russia-based entities that import dual-use technology from abroad. Eleven Russia-based entities were designated today, involved in the development and distribution of electronic compenents.
Russia-based entities designated for operating in the defense and related materiel sector include four producers of explosives and ammunition, a producer of components for rocket systems, missiles, and bombs, And the National Centre of Laser Systems and Complexes (Astrofizika) a research and development center focused on laser and optical technologies.
OFAC is also targeting entities in key industries such as aerospace, quantum technologies, and advanced computing including research institutes and other entities that support Russia’s research and development of high-technology goods. Designations include six government institutes focused on physics and informatics and a private company involved in superconducting nanotechnology
Five Russian banks were designated, including Tinkoff Bank, partially owned by U.S.-designated Vladimir Olegovich Potanin. Related to these sanctions, OFAC issued and Russia-related General License 71, "Authorizing the Wind Down and Rejection of Transactions Involving Certain Entities Blocked on July 20, 2023."
Ural Mining and Metallurgical Company one of Russia’s top producers of metals such as copper, zinc, gold, and silver, and affiliates involved in the non-ferrous metals processing industry, as well as a Russia-based UMMC subsidiary involved in the refining of precious metals, cathodes, and bullion products.
Along with the above designations, OFAC is issuing Russia-related General License 70, "Authorizing the Wind Down of Transactions Involving Joint Stock Company Ural Mining and Metallurgical Company"
Seven Russia-based manufacturers of energy industry equipment were designated, as well as four manufacturers of energy-related refining agents and Tyumen Petroleum Research Center, Rosneft’s corporate research and design institute. TPRC, which is involved in technology development, performs field engineering and support for geological survey processes and is involved in the development of oil and gas fields in Russia and elsewhere for Rosneft subsidiaries.
The Fund for Development of Energy Complex Energy (Fund Energy) is a Russia-based investment house that invests in energy, oil and gas, and mining enterprises and infrastructure facilities.
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 exempt or authorized by a general or specific license issued by OFAC.
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