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Sanctions target individuals and entities in 17 jurisdictions; Deputy Secretary calls on countries to take similar action against enablers of Russia’s military-industrial baseWASHINGTON — Today, the U.S. Department of the Treasury sanctioned 275 individuals and entities involved in supplying Russia with advanced technology and equipment that it desperately needs to support its war machine. Today’s action targets both individual actors and sprawling sanctions evasion networks across 17 jurisdictions, including India, the People’s Republic of China (PRC), Switzerland, Thailand, and Türkiye. In addition to disrupting global evasion networks, this action also targets domestic Russian importers and producers of key inputs and other materiel for Russia’s military-industrial base.“The United States and our allies will continue to take decisive action across the globe to stop the flow of critical tools and technologies that Russia needs to wage its illegal and immoral war against Ukraine,” said Deputy Secretary of the Treasury Wally Adeyemo. “As evidenced by today’s action, we are unyielding in our resolve to diminish and degrade Russia’s ability to equip its war machine and stop those seeking to aid their efforts through circumvention or evasion of our sanctions and export controls.”The Department of State is also targeting sanctions evasion and circumvention in multiple third countries, including several PRC-based companies exporting dual-use goods that fill critical gaps in Russia’s military-industrial base and entities and individuals in Belarus related to the Lukashenka regime’s support for Russia’s defense industry. State is also targeting several senior Russian Ministry of Defense officials and defense companies and those supporting Russia’s future energy production and exports. SANCTIONS EVASION, CIRCUMVENTION, AND BACKFILLThanks to the unprecedented international sanctions regime implemented by the United States and its global partners, Russia is ever more reliant on complex and expensive transnational schemes to procure critical technological and manufacturing components and machinery it needs to create its own weapons production capability. This includes sensitive dual-use goods such as those cited in the Department of Commerce’s Bureau of Industry and Security’s multilateral Common High Priority List (CHPL), developed by the United States, European Union, Japan, and the United Kingdom. Today’s action by Treasury disrupts a number of those schemes by designating more than 120 individuals and entities, including those involved in illicit procurement networks and the financial facilitators that support them. Financial facilitators such as trust and corporate formation service providers—several of which were sanctioned today—are key nodes in sanctions evasion ecosystems, and actions against them can act as force multipliers by rippling disruptive effects through multiple sanctions evasion networks simultaneously.Many of today’s designations were enabled or informed with support from Treasury’s Financial Crimes Enforcement Network (FinCEN). For more information on these targets, please see Annex 1. RUSSIA’S MILITARY-INDUSTRIAL BASE Treasury is also targeting more than 150 Russia-based defense and related materiel, technology, manufacturing, and aerospace companies that procure or produce finished military products or key components, precursors, and machinery that enable Russia to build or maintain the weaponry it uses against Ukraine. For more information on these targets, please see Annex 2. ANNEX 1: SANCTIONS EVASION, CIRCUMVENTION, AND BACKFILLRussian Defense Procurement Networks Operating in TürkiyeOFAC is targeting 14 entities and nine individuals, based primarily in Türkiye, that have facilitated the procurement of advanced weapons, components, and ammunition on behalf of Russian end-users critical to bolstering Russia’s military campaign, including the Russian Ministry of Defense and state-owned defense companies. This action, intended to disrupt Russian procurement efforts, comes after extensive consultation with the Government of Türkiye. The United States is committed to taking all necessary measures to protect the U.S., Turkish, and international financial systems.Mirex NetworkTürkiye-based Mirex Havacilik ve Savunma Sanayi Ticaret Anonim Serketi (Mirex) and its chairman, Turkish national Ozgur Hasan Celik (Celik), have been involved in contracts with Russian government-affiliated defense companies to deliver and facilitate electronic warfare system demonstrations in Russia. Mirex has led efforts to locally assemble and manufacture equipment for Russian defense companies in Türkiye. Celik is the manager and co-owner of Bulgaria-based GNO Investment LTD OOD (GNO Investment), which he uses to facilitate Mirex’s defense production and procurement activities. Celik is also the manager and co-owner of Bulgaria-based Mirex BG LTD OOD (Mirex BG). Celik has also worked with U.S.-designated Russian defense conglomerate State Corporation Rostec (Rostec)’s representative in Türkiye, Aleksey Viktorovich Gureyev (Gureyev), on efforts to manufacture Russian defense equipment in Türkiye using Mirex. Russian national Mikhail Alekseyevich Klementyev (Klementyev) works alongside Gureyev as the Rostec Deputy representative in Türkiye.Mirex is being designated pursuant to Executive Order (E.O.) 14024 for operating or having operated in the defense and related material sector of the Russian Federation economy. Celik is being designated pursuant to E.O. 14024 for having acted or purported to act for or on behalf of, directly or indirectly, Mirex. GNO and Mirex BG are being designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Celik. Gureyev and Klementev are being designated pursuant to E.O. 14024 for having acted or purported to act for or on behalf of, directly or indirectly, Rostec.GRU-linked Turkish CompanyTürkiye-based New Way Group Global Danismanlik Ticaret Limited Sirketi (New Way) has been used by Russia’s U.S.-designated Main Intelligence Directorate (GRU) to facilitate shipments of U.S.-origin microelectronics and production and testing equipment to Russia. New Way is being designated pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector of the Russian Federation economy.Sanlitun NetworkRussian national Alexander Vladimirovich Kalinin (Kalinin), Turkish national Ahmet Furgan Albayrak (Albayrak), and U.S.-designated individual Anselm Oskar Schmucki (Schmucki) used their Türkiye-based company Sanlitun Yatirim Dis Ticaret Limited (Sanlitun) to acquire Western electronic components for Russian customers, including for Russian state defense orders. Albayrak, a director of Sanlitun, worked with Kalinin to submit equipment orders through Sanlitun for Russia, falsifying the end use of the equipment on at least one occasion. Sanlitun is being designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy. Kalinin and Albayrak are being designated pursuant to E.O. 14024 for having acted or purported to act for or on behalf of, directly or indirectly, Sanlitun.Greek national Petros Nikolaos Contoguris (Contoguris) worked with Kalinin at Sanlitun to arrange for the export of hazardous material using U.S.-designated Russian metals company Aktsionernoe Obshchestvo Evraz Vanadi Tula (Tula). Contoguris designed a convoluted and obfuscated way to import the substance to evade international sanctions. Contoguris also worked with Kalinin to provide refurbished gas turbines to Russia through Sanlitun, and Contoguris and Kalinin have supported multiple Russian customers. Contoguris is being designated pursuant to E.O. 14024 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Kalinin.Nitrocellulose ShipmentsRussia-based freight logistics company LLC AM Logistics (AM Logistics) has taken delivery of multiple shipments of nitrocellulose, a chemical compound that is a key ingredient in modern gunpowder, explosives, and artillery shells, in Russia. Türkiye-based SLD Lojistik Ic ve Dis Ticaret Limited Sirketi (SLD Lojistik) has conducted several large shipments of nitrocellulose to Russian companies, including AM Logistics. Russian national Daria Aleksandrovna Shachenok (Shachenok) is the director and owner of AM Logistics and the 50-percent owner of SLD Lojistik.AM Logistics is being designated pursuant to E.O. 14024 for operating or having operated in the transportation sector of the Russian Federation economy. SLD Lojistik is being designated pursuant to E.O. 14024 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, АМ Logistics. Shachenok is being designated pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of, AM Logistics.Tool Company GutRussia-based Tool Company Gut Limited Liability Company (Tool Company Gut) has imported computer numerically controlled (CNC) machine tools and components, high priority items crucial to Russia’s war efforts, from Türkiye-based entities. Tool Company Gut has historically supplied tools and parts to entities in the Russian defense sector and has continued to contract and interact with Russian defense sector entities. Russia-based Limited Liability Company Mobula (Mobula), which is co-located with Tool Company Gut, has imported interchangeable tools for hand- or machine-tools from Türkiye-based entities. Türkiye-based Modulsan Makina Kesici Takim ve Disli Sanayi Ticaret Limited Sirketi (Modulsan) has exported manufacturing articles for making metal-cutting tools to Russia, including to Tool Company Gut. Tool Company Gut, Mobula, an…

Treasury Takes Aim at Third-Country Sanctions Evaders and ...

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Aleksey Postovoy

Head specialist of the development programmes division "Gazpromneft-ONPZ"

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