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3/25/2024

Treasury Designates Russian Companies Supporting Sanctions Evasion Through Virtual Asset Services and Technology …

Treasury Designates Russian Companies Supporting Sanctions
Evasion Through Virtual Asset Services and Technology
Procurement
March 25, 2024

WASHINGTON — Today, the Department of the Treasuryʼs O ice of Foreign Assets Control
(OFAC) sanctioned thirteen entities and two individuals for operating in the financial services
and technology sectors of the Russian Federation economy including persons developing or
o ering services in virtual assets that enable the evasion of U.S. sanctions. Five entities were
designated for being owned or controlled by OFAC-designated persons.
Many of the individuals and entities designated today facilitated transactions or o ered
other services that helped OFAC-designated entities evade sanctions. These designations
build upon OFACʼs February 23, 2024 action to target companies servicing Russiaʼs core
financial infrastructure and curtail Russiaʼs use of the international financial system to further
its war against Ukraine.
“Russia is increasingly turning to alternative payment mechanisms to circumvent U.S.
sanctions and continue to fund its war against Ukraine,” said Under Secretary of the Treasury
for Terrorism and Financial Intelligence, Brian E. Nelson. “As the Kremlin seeks to leverage
entities in the financial technology space, Treasury will continue to expose and disrupt the
companies that seek to help sanctioned Russian financial institutions reconnect to the global
financial system.”

COUNT ERING T HE POT ENT IAL F OR SANCT IONS EVASION
W IT H VIRT UAL ASSETS
On February 24, 2024, the G7 Leaders rea irmed their commitment to step up e orts against
the evasion and circumvention of G7 sanctions and export control measures. The companies
designated by OFAC today have all either helped build or operate blockchain-based services
for, or enabled virtual currency payments in, the Russian financial sector, thus enabling
potential sanctions evasion.

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Treasury Designates Russian Companies Supporting Sanctions Evasion Through Virtual Asset Services and Technology …

Joint Stock Company B-Crypto (B-Crypto) is a Moscow-based fintech company that has
partnered with OFAC-designated Rosbank to facilitate cross-border settlements for Russian
exporters using virtual currencies. B-Crypto was designated pursuant to E.O. 14024 for
operating or having operated in the financial services sector of the Russian Federation
economy.
Obshchestvo S Ogranichennoy Otvetstvennostyu Sistemy Raspredelennogo
Reyestra (Masterchain) is a Moscow-based fintech company that has agreements to issue
digital financial assets, a term in Russiaʼs legal framework that refers to blockchain-based
tokens that confer digital rights, with various OFAC-designated Russian banks, including VTB
Bank and the Central Bank of Russia. Masterchain was designated pursuant to E.O. 14024 for
operating or having operated in the financial services sector of the Russian Federation
economy.
Obshchestvo S Ogranichennoy Otvetstvennostyu Laitkhaus (Laitkhaus) is a Moscowbased fintech company that has worked with OFAC-designated Sberbank and VTB Bank to
issue, exchange, and transfer digital financial assets. Laitkhaus was designated pursuant to
E.O. 14024 for operating or having operated in the financial services sector of the Russian
Federation economy.
Obshchestvo S Ogranichennoy Otvetstvennostyu Atomaiz (Atomaiz), a Moscow-based
fintech company, is a registered digital financial asset operator that has worked to tokenize
precious metals and diamonds for Russian companies and is partnered with OFAC-designated
Rosbank and Sovcombank. Atomaiz was designated pursuant to E.O. 14024 for operating or
having operated in the financial services sector of the Russian Federation economy.
Tokentrust Holdings Ltd., based in Cyprus, is the majority shareholder of Atomaiz and was
designated pursuant to E.O. 14024 for operating or having operated in the financial services
sector of the Russian Federation economy.
Obshchestvo S Ogranichennoy Otvetstvennostyu Veb3 Tekhnologii (Veb3 Tekhnologii)
and Obshchestvo S Ogranichennoy Otvetstvennostyu Veb3 Integrator (Veb3 Integrator)
are Moscow-based technology companies providing blockchain solutions and platforms within
the Russian financial sectors, with clients including OFAC-designated Sberbank and Alfa-Bank.
Veb3 Tekhnologii and Veb3 Integrator were designated pursuant to E.O. 14024 for operating
or having operated in the technology sector of the Russian Federation economy.

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Treasury Designates Russian Companies Supporting Sanctions Evasion Through Virtual Asset Services and Technology …

Igor Veniaminovich Kaigorodov is the majority shareholder at both Veb3 Tekhnologii and
Veb3 Integrator and was designated pursuant to E.O. 14024 for operating or having operated
in the technology sector of the Russian federation economy.
Obshchestvo S Ogranichennoy Otvetstvennostyu Tsentr Obrabotki Elektronnykh
Platezhey (TOEP), under its business names Netexchange and Netex24, is a Moscow-based
fintech company that operates a virtual currency exchange which has enabled digital
payments in rubles and virtual currencies to OFAC-designated entities such as Sberbank, AlfaBank, and Hydra Market. TOEP was designated pursuant to E.O. 14024 for operating or having
operated in the financial services sector of the Russian Federation economy.
Timur Evgenyevich Bukanov (Bukanov) is the owner and director of TOEP and was
designated pursuant to E.O. 14024 for operating or having operated in the financial services
sector of the Russian Federation economy.
Bitfingroup OÜ (Bitfingroup) is an Estonian company that lists Bukanov as the sole owner.
Bitfingroup was designated for being owned or controlled by, or having acted or purported to
act for or on behalf of, directly or indirectly, Bukanov.
Bitpapa IC FZC LLC (Bitpapa) operates a peer-to-peer virtual currency exchange and o ers
services to Russian nationals. To date, it has conducted transactions worth millions of dollars
with OFAC-designated Russian entities Hydra Market and Garantex. Bitpapa was designated
pursuant to E.O. 14024 for operating or having operated in the financial services sector of the
Russian Federation economy.
Crypto Explorer DMCC (Crypto Explorer), under its business name AWEX, operates a Russia
and UAE-based virtual currency exchange that o ers conversions between virtual currencies,
rubles, and UAE dirhams. AWEX o ers cash services at its o ices in Moscow and Dubai and
also loads funds onto credit cards associated with OFAC-designated Russian banks such as
Sberbank and Alfa-Bank. Crypto Explorer was designated pursuant to E.O. 14024 for operating
or having operated in the financial services sector of the Russian Federation economy.
Obshchestvo S Ogranichennoy Otvetstvennostyu Kripto Eksplorer (OOO Kripto Eksplorer)
is a Russian company that is solely owned by Crypto Explorer. OOO Kripto Eksplorer was
designated for being owned or controlled by, or having acted or purported to act for or on
behalf of, directly or indirectly, Crypto Explorer.

DISRUPT ING RUSSIAʼS T ECHNOLOGY PROCUREMENT
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Treasury Designates Russian Companies Supporting Sanctions Evasion Through Virtual Asset Services and Technology …

Joint Stock Company Echelon Technologies (Echelon Technologies) is a Moscow-based
company that sells technology products and is owned by Joint Stock Company Echelon Union
for Science and Technology (Echelon Union) an OFAC-designated entity licensed by the
Russian Federal Security Service and the Russian Ministry of Defense. Echelon Technologies
was designated pursuant to E.O. 14024 for operating or having operated in the technology
sector of the Russian Federation economy.
Autonomous Non-Profit Organization of Additional Professional Education Echelon
Training Center and Limited Liability Company Key Information Systems are Moscowbased companies that work with and share an address with OFAC-designated Echelon Union
and were designated pursuant to E.O. 14024 for operating or having operated in the
technology sector of the Russian Federation economy.
Limited Liability Company Echelon Innovations (Echelon Innovations), Limited Liability
Company Project Consulting Bureau Echelon (Project Bureau Echelon), and Limited
Liability Company Cybersecurity Laboratory (Cybersecurity Laboratory) all list Echelon
Union as the sole or majority shareholder. Echelon Innovations, Project Bureau Echelon, and
Cybersecurity Laboratory were designated for being owned or controlled by, or having acted
or purported to act for or on behalf of, directly or indirectly, Echelon Union.

SANCT IONS IMPLICAT IONS
As a result of todayʼs action, all property and interests in property of the designated persons
described 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, individually or in the aggregate, 50 percent or more by one or more blocked
persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or
exempt, OFACʼs regulations generally prohibit all transactions by U.S. persons or within (or
transiting) the United States that involve any property or interests in property of designated
or otherwise blocked persons.
In addition, foreign financial institutions that conduct or facilitate significant transactions or
provide any service involving Russiaʼs military-industrial base run the risk of being sanctioned
by OFAC. Examples of activities that could expose foreign financial institutions to sanctions
risk under E.O. 14024, as amended, are maintaining accounts, transferring funds, or providing
other financial services (i.e., payment processing, trade finance, insurance) for any persons
designated for operating in the specified sectors or for any persons, either inside or outside
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Russia, that support Russiaʼs military-industrial base, including those that operate in the
specified sectors of the Russian Federation economy. For additional guidance, please see
the December 22, 2023 OFAC Sanctions Advisory as well as OFAC Frequently Asked Questions
(FAQs) 1146-1157.
The power and integrity of OFAC sanctions derive not only from OFACʼs ability to designate
and add persons to the SDN List, but also from its willingness to remove persons from the
SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring
about a positive change in behavior. For information concerning the process for seeking
removal from an OFAC list, including the SDN List, please refer to OFACʼs Frequently Asked
Question 897 here. For detailed information on the process to submit a request for removal
from an OFAC sanctions list, please click here.
Click here for more information on the individuals and entities designated today.
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