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5/16/2024

Treasury Designates Sanctions Evaders Facilitating Illicit Arms Transfers between the DPRK and Russia | U.S. Departme…

Treasury Designates Sanctions Evaders Facilitating Illicit Arms
Transfers between the DPRK and Russia
May 16, 2024

WASHINGTON — Today, the U.S. Department of the Treasuryʼs O ice of Foreign Assets
Control (OFAC) is imposing sanctions on two Russian individuals and three Russia-based
entities for facilitating weapons transfers between Russia and the Democratic Peopleʼs
Republic of Korea (DPRK). This action promotes U.S. government objectives to disrupt and
expose arms transfers between the DPRK and Russia and builds upon sanctions imposed by
the Department of the Treasury and the Department of State related to DPRK-Russia arms
transfers, including the transfer and testing of DPRK-origin ballistic missiles for Russiaʼs use
against Ukraine. This action demonstrates our resolve to impose costs on and hold the DPRK
and Russia to account for their unlawful activities.
“Todayʼs action reflects our commitment to disrupt the DPRKʼs deepening military
cooperation with Russia,” said Under Secretary of the Treasury for Terrorism and Financial
Intelligence Brian E. Nelson. “The United States will continue to take action to hold
accountable those who seek to facilitate the shipment of weapons and other materiel to
enable Russiaʼs war.”

DPRK-RUSSIA ILLICIT T RADE AND MUNIT IONS
T RANSF ERS
Russia and the DPRK have strengthened their military cooperation over the past year, with the
DPRK providing ballistic missiles and munitions to Russia. In return for its support to Moscow,
Pyongyang is seeking military assistance from Russia. These designations target individuals
and companies facilitating Russia-DPRK military cooperation. Operating through networks
located in Russia, these actors attempt to evade sanctions by using front companies to move
military equipment to support Russiaʼs illegal aggression against Ukraine.
In March 2023, OFAC designated Ashot Mkrtychev (Mkrtychev) for attempting to facilitate
arms deals between Russia and the DPRK. In August 2023, OFAC designated three additional
companies, including Verus LLC, a Russia-based company tied to Mkrtychevʼs sanctions
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Treasury Designates Sanctions Evaders Facilitating Illicit Arms Transfers between the DPRK and Russia | U.S. Departme…

evasion network. Since these designations, Mkrtychev and his associates have continued to
facilitate the shipment of DPRK military equipment to Russia.
Throughout 2023, Rafael Anatolyevich Gazaryan (Gazaryan) worked with Mkrtychev on
arms transactions involving the DPRK and Russia. Since at least April 2023 Gazaryan has acted
as a point of contact for Mkrtychevʼs negotiations to obtain multiple kinds of weapons and
munitions for Russia from the DPRK. In May 2023, Gazaryan likely acted as an intermediary
between a Russian government o icial and Mkrtychev. As recently as June 2023, Gazaryan
worked on purchasing certain components on Mkrtychevʼs behalf. At the time of Verus LLCʼs
2023 designation Gazaryan was also the companyʼs director. During October 2023, Gazaryan
coordinated with Mkrtychev on commercial proposals involving mortars and mortar shells.
Gazaryan also used Russian-based Trans Kapital Limited Liability Company to facilitate the
shipment and delivery of aviation components to a North Korean weapons dealer. Gazaryan is
the owner of Russia-based Rafort Limited Liability Company.
As recently as March 2023, Aleksey Budnev (Budnev) has facilitated shipments to Russia of
military communications equipment that likely originated from the DPRK intended to support
the Russian military. Budnev is the sole owner of Russia-based Tekhnologiya, OOO.
Rafael Anatolyevich Gazaryan is being designated, pursuant to Executive Order 13551 (E.O.
13551), for having materially assisted, sponsored, or provided financial, material, or
technological support for, or goods or services to or in support of, Ashot Mkrtychev, an
individual whose property and interests in property are blocked pursuant to E.O. 13551.
Trans Kapital Limited Liability Company is being designated, pursuant to E.O. 13551, for
having materially assisted, sponsored, or provided financial, material, or technological support
for, or goods or services to or in support of Rafael Anatolyevich Gazaryan, an individual whose
property and interests in property are blocked pursuant to E.O. 13551.
Rafort Limited Liability Company is being designated, pursuant to E.O. 13551, for being owned
or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly,
Rafael Anatolyevich Gazaryan, an individual whose property and interests in property are
blocked pursuant to E.O. 13551.
Aleksey Budnev is being designated for having directly or indirectly imported, exported, or
reexported to, into, or from North Korea any arms or related materiel.
Tekhnologiya, OOO is being designated, pursuant to E.O. 13551, for being owned or controlled
by, or having acted or purported to act for or on behalf of, directly or indirectly,
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Aleksey Budnev, an individual whose property and interests in property are blocked pursuant
to E.O. 13551.

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, financial institutions and other persons that engage in certain transactions or
activities with the sanctioned entities and individuals may expose themselves to sanctions or
be subject to an enforcement action. The prohibitions include the making of any contribution
or provision of funds, goods, or services by, to, or for the benefit of any designated person, or
the receipt of any contribution or provision of funds, goods, or services from any such person.
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. For detailed information on the process to submit a request for removal from
an OFAC sanctions list.
Click here for more information on the individuals and entities designated today.
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