Bass, Berry & Sims’ international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to customers on how to handle the situation. This post summarizes the evolution of the situation in Thursday, March 31st regarding current US sanctions and export restrictions related to Russia and Ukraine. This article complements our previous analysis, all of which link to the end of today’s content.
US targets Russian sanctions evaders in latest round of designations
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 carrying out any transaction with an SDN.
The designations cover several different Russian players, including network and front companies involved in supplying Western technologies to the Russian defense sector as follows:
- OOO Serniya Engineering (Serniya), based in Moscow.
- OOO Sertal (Sertal), based in Moscow.
- The Russian company OOO Robin Treid (Front company of Serniya).
- Majory LLP based in K. (Front company for Serniya).
- Photon Pro LLP, based in K. (front company for Serniya).
- Based in Spain, Invention Bridge SL (representing Serniya).
- Singapore-based Alexsong Pte Ltd (Serniya Sanctions Circumvention Support).
Individual representatives of the company, directors also appointed
In addition to entities, OFAC has designated persons acting on behalf of or to be officers, officers, senior managers, or members of the board of directors of sanctioned companies:
- Irina Viktorovna Nikolaeva (acting on behalf of Serniya).
- Yevgeniya Aleksandrovna Podgornova (acting on behalf of Serniya).
- Sergey Aleksandrovich Yershov (acting on behalf of Serniya).
- Anton Alekseevich Krugovov (acting on behalf of Serniya and senior officer of Majory LLP).
- Andrey Georgiyevich Zakharov (acting on behalf of Serniya).
- Yevgeniy Aleksandrovich Grinin (acting on behalf of Serniya and leader of Photon Pro LLP).
- Sergey Aleksandrovish Yershov (a leader of Serniya and acting on behalf of Sertal).
- Viacheslav Yuryevich Dubrovinskiy (a ruler 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 company’s role in acquiring dual-use goods
OFAC named Evgeniya Vladimirovna Bernova and some of his companies operating in Europe, as well as a director of one of the companies, for their role in acquiring dual-use equipment for Russian end users :
- Malberg Ltd based in Malta (Bernova company).
- Nikita Alexsandrovich Sobolev (director of Malberg).
- Djeco Group LP based in K. (Bernova front company).
- Djeco Group Holding Ltd, based in Malta (front company of Bernova).
- Malterent Ltd. (Front company of Bernova).
- SCI Griber based in France (front company of Bernova).
- Sernia-Film Co. Ltd, based in Moscow (Bernova served as director).
Russian tech companies designated to enable war
OFAC has designated the following communications and electronics companies to operate in the Russian technology sector and support the Russian war effort:
- AO NII-Vektor, 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 microelectronics manufacturer/exporter (for production of chips for Mir, Russia’s national payment card system).
- Molecular Electronics Research Institute, R&D Institute (for research and design work for the Russian government).
Treasury expands Russia Sanctions Authority
Also today, Treasury Secretary Yellen issued a decision pursuant to Executive Order (EO) 14024 that extends sanctions to companies operating in Russia’s aerospace, marine, and/or electronics sectors. Although no sanctions against the parties in these sectors have yet been announced, the determination paves the way for such sanctions. This builds on previous determination related to the financial services sector of the Russian economy and initial authority under EO 14024, which established the power to impose sanctions on parties in the technology sectors. and defense of the Russian economy.
OFAC continues to designate Russian and other actors, even without a direct connection to Ukraine
Although not directly related to Russia’s invasion of Ukraine, OFAC also announced that it is designating employees of the State Research Center of the Central Scientific Research Institute of Chemistry and Mechanical Engineering of the Russian Federation (TsNIIKhM) for their role in the August 2017 cyberattack on a Central Eastern Petrochemical Facility. These individuals are:
- Evgeny Viktorovich Gladkikh, an employee of the TsNIIKhM Applied Development Center.
- Servei Alekseevich Bobkov, general director of TsNIIKhM.
- Konstantin Vasilyevich Malevanyy, Deputy General Director of TsNIIKhM.
Also today, OFAC named Quantlog OY, a Finnish front company set up by Nikita Gennadievich Kovalevskij, a person named in September 2020 for his involvement in the purchase of scuba diving equipment for the Federal Security Service (FSB) Russian.