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3/20/2024

Treasury Sanctions Actors Supporting Kremlin-Directed Malign Influence Efforts | U.S. Department of the Treasury

Treasury Sanctions Actors Supporting Kremlin-Directed Malign
Influence Efforts
March 20, 2024

WASHINGTON — Today, the Department of the Treasuryʼs O ice of Foreign Assets Control
(OFAC) designated two individuals and two entities for services they provided the
Government of the Russian Federation (GoR) in connection with a foreign malign influence
campaign, including attempting to impersonate legitimate media outlets.
“We are committed to exposing Russiaʼs extensive campaigns of government-directed
deception, which are intended to mislead voters and undermine trust in democratic
institutions in the United States and around the world,” said Under Secretary of the Treasury
for Terrorism and Financial Intelligence Brian E. Nelson. “The United States, along with our
allies and partners, remains steadfast in defending our democratic principles and the
credibility of our elections.”

RUSSIAN F OREIGN MALIGN INF LUENCE
Moscow employs an array of tools, including malign influence campaigns and illicit cyber
activities, to undermine the interests of the United States and its allies and partners,
including in Latin America, the Middle East, and Europe. Russia routinely uses its intelligence
services, proxies, and influence tools in these e orts. Russiaʼs influence actors have
increasingly adapted their methods to hide their involvement by developing a vast ecosystem
of Russian proxy websites, personas, and organizations which give the false appearance of
being independent news sources.
Todayʼs designations follow prior OFAC actions that have highlighted and disrupted Russiaʼs
global malign influence campaigns, which have included U.S. election interference, e orts to
subvert democracy in Moldova, destabilization activities in Ukraine, and the operation of
outlets controlled by Russian intelligence services, among others.

RUSSIAN AGENTS IMPLEMENT ING T HE KREMLINʼS
DIRECT IVES TO DECEIVE AUDIENCES
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Treasury Sanctions Actors Supporting Kremlin-Directed Malign Influence Efforts | U.S. Department of the Treasury

Ilya Andreevich Gambashidze (Gambashidze), the founder of the Moscow-based company
Social Design Agency (SDA), together with Nikolai Aleksandrovich Tupikin (Tupikin), the
CEO and current owner of Russia-based Company Group Structura LLC (Structura), were
involved in a persistent foreign malign influence campaign at the direction of the Russian
Presidential Administration. SDA and Structura have been identified as key actors of the
campaign, responsible for providing GoR with a variety of services, including the creation of
websites designed to impersonate government organizations and legitimate media outlets in
Europe.
Leading into Fall 2022, Tupikin and Gambashidze implemented a campaign that
impersonated news websites, staged videos, and fake social media accounts. Specifically,
Tupikin and Gambashidze, via SDA and Structura, have implemented, on behalf of GoR, a
sprawling network of over 60 websites that impersonated legitimate news organizations, and
which used misleading social media accounts to amplify the content of the spoofed websites.
The fake websites appeared to have been built to carefully mimic the appearance of legitimate
news websites. The fake websites included embedded images and working links to legitimate
sites and even used the impersonated siteʼs cookie acceptance page.
Today, OFAC designated SDA and Structura 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,
GoR.
OFAC designated Gambashidze and Tupikin pursuant to E.O. 14024 for being or having been
a leader, o icial, senior executive o icer, or member of the board of directors of SDA and
Structura, respectively, persons whose property and interests in property are blocked
pursuant to E.O. 14024.

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.
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Treasury Sanctions Actors Supporting Kremlin-Directed Malign Influence Efforts | U.S. Department of the Treasury

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 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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