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12/5/2023

Treasury Targets Belarusian Revenue Generators for Lukashenka, Human Rights Abuses, and Cogs in Russia’s War Ma…

Treasury Targets Belarusian Revenue Generators for
Lukashenka, Human Rights Abuses, and Cogs in Russia’s War
Machine
December 5, 2023

WASHINGTON — Today, the U.S. Department of the Treasuryʼs O ice of Foreign Assets
Control (OFAC) is designating 11 entities and seven individuals pursuant to Executive Order
(E.O.) 14038 and one individual pursuant to E.O. 14024. This action increases the pressure on
Alyaksandr Lukashenkaʼs (Lukashenka) authoritarian regime for its brutal suppression of
Belarusʼs democratic civil society, corrupt financial enrichment of the Lukashenka family, and
complicity in Russiaʼs unjustified war against Ukraine.
“Todayʼs action rea irms our e orts to hold Lukashenka, his family, and his regime
accountable for their anti-democratic actions and human rights abuses, both in Belarus and
around the world,” said Under Secretary of the Treasury for Terrorism and Financial
Intelligence Brian E. Nelson. “We will continue to target the Lukashenka regimeʼs revenue
generators, his so-called personal ʻwallets,ʼ and actors who facilitate Russiaʼs war of
aggression in Ukraine, coordinate the movement of children from Ukraine to Belarus, and
support Lukashenkaʼs authoritarian regime.”

B ELARUSʼS COMPLICIT Y IN DEPORTAT ION OF UKRAINIAN
CHILDREN
Dzmitry Shautsou (Shautsou) is the Secretary General for the Belarus Red Cross. Since the
start of Russiaʼs invasion of Ukraine, Russia has been transferring hundreds of thousands of
children from Ukraine to Russia. Belarus has been complicit and supportive of Russiaʼs e orts
to collect and transport Ukrainian children to Belarus. The International Criminal Court has
issued arrest warrants for both Russian President Vladimir Putin and the Commissioner for
Children's Rights in the O ice of the President of the Russian Federation Maria Lvova-Belova
for their roles in the unlawful deportation and transfer of children from Russia-occupied areas
of Ukraine.

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Russiaʼs federal government and Belarusʼ regime have been working together to coordinate
and fund the movement of children from Ukraine to Belarus. Both Ukraine and the Belarusian
democratic opposition have labelled the transfers unlawful deportations. In June 2023, the
Belarusian Red Cross reported that more than 700 Ukrainian children were in Belarus. In
July 2023, the Belarus Red Cross sparked international outrage due during Shautsouʼs
visitation of children in Luhansk, Ukraine, where Shautsou claimed on Belarus state television
that the organization has been actively involved in bringing Ukrainian children from Russianoccupied areas of Ukraine to Belarus. Additionally, Shautsouʼs appearance in Luhansk was
ultimately in aid of Lvova-Belova-led Russian government e orts to remove Ukrainian children
from Russian-occupied area of Ukraine to Belarus. In November 2023, Lvova-Belova met with
the Plenipotentiary Ambassador of Russia to Belarus to plan out next joint steps for the
protection of children.
On October 4, 2023, IFRC called for Shautsouʼs removal, and on December 1, 2023, IFRC
suspended the membership of the Belarus Red Cross Society for non-compliance with this
order due to their refusal to remove him from his position.
OFAC is designating Shautsou 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, Maria Lvova-Belova, a person whose property and interests in property are
blocked pursuant to E.O. 14024.

LUKASHENKAʼS ʻW ALLETSʼ AND REGIME REVENUE
GENERATORS
Aliaksandr Shakutsin (Shakutsin) is a member of Lukashenkaʼs inner circle and is one of the
leading businessmen in Belarus, having made his fortune benefitting from privatization under
Lukashenka. Shakutsin has served as one of Lukashenkaʼs closest supporters and as one of his
ʻwallets,ʼ providing funds to Lukashenka and his regime in exchange for preferential treatment
and benefits. In 2020, Shakutsin openly backed Lukashenka in the wake of Belarusʼs fraudulent
election and denigrated pro-democracy protestors as the Regime began to initiate its
widespread repression of civil liberties. Shakutsin, who has already been sanctioned by
numerous U.S. allies, continues to attempt to evade sanctions through front companies in
Europe and the Middle East, and regularly violates machinery import bans into Belarus and
Russia.

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OFAC is designating Shakutsin pursuant to E.O. 14038 for operating or having operated in the
construction sector of the Belarus economy.
Through his primary business, Open Joint Stock Company Management Holding Company
Amkodor (Amkodor), Shakutsin controls a considerable piece of Belarusʼs construction
machinery and machinery components production. Since at least 2021, Shakutsin has
personally o ered Amkodorʼs services as a developer of defense technology to Lukashenka
and the Belarusian Armed Forces. Amkodor is currently developing and planning to produce
attack drones and artillery fire systems, which representatives from Amkodor and the
Belarusian Armed Forces have described as having high export potential. Despite running a
deficit for years, Amkodor has relied on Shakutsinʼs personal relationship with Lukashenka to
secure highly favorable loans and other forms of public support at the expense of the average
Belarusian. Amkodor has greatly expanded its footprint in Russia following the withdrawal of
foreign businesses in the wake of Russiaʼs war of aggression in Ukraine, and Amkodor has
received loans and preferential treatment from the Russian government as well.
OFAC is designating Amkodor pursuant to E.O. 14038 for operating or having operated in the
construction sector of the Belarus economy.
Republican Production and Trade Unitary Enterprise Management Company of the
Holding Belarusian Cement Company (BCC) is a state-owned enterprise that unites large
cement plants in Belarus into a collective holding with a combined production capacity of
approximately 5 million tons per year. Reduced export volumes to the European Union (EU)
following sectoral EU sanctions in June 2022 have resulted in BCC increasing its exports to
Russia to compensate. BCC exported a record 2.3 times more cement to Russia in April 2023
than in April 2022.
OFAC is designating BCC pursuant to E.O. 14038 for being owned or controlled by, or having
acted or purported to act for or on behalf of, directly or indirectly, the Government of Belarus
(GoB).
Belarusian Production and Trade Concern of Timber Woodworking and Pulp and Paper
Industry (Bellesbumprom)is a state-owned enterprise whose activities are divided into three
sectors: (1) logging, including procurement and hauling of timber and its cross-cutting;
production of industrial wood and wood products; production of sawlog, veneer, matchbox
and technological raw materials; and resin extraction; (2) pulp and paper industry specialized
in the production of cardboard and paper products with over 20 types of paper and cardboard;
and (3) woodworking and furniture production.
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OFAC is designating Bellesbumprom pursuant to E.O. 14038 for being owned or controlled by,
or having acted or purported to act for or on behalf of, directly or indirectly, the GoB.
Republican Unitary Enterprise Beltamozhservice (Beltamozhservice) is a state-owned
Belarusian logistics provider that operates under Belarusʼs State Customs Committee.
Through its position as a state-owned enterprise and as Belarusʼs o icial customs
representative, Beltamozhservice is a major revenue generator for the Lukashenka regime and
has facilitated large-scale smuggling schemes into Russia for the benefit of oligarchs and the
Lukashenka regime. Both the EU and Canada have also designated Beltamozhservice for
benefitting and supporting the Lukashenka regime and for committing a grave breach of
international peace and security, respectively.
OFAC is designating Beltamozhservice pursuant to E.O. 14038 for being owned or controlled
by, or having acted or purported to act for or on behalf of, directly or indirectly, the GoB.
Vadim Aleksandrovich Babarikin (Babarikin) serves as the General Director of
Beltamozhservice and its branches. OFAC is designating Babarikin pursuant to E.O. 14038 for
being or having been a leader or o icial of the GoB.
Pavel Georgievich Topuzidis (Topuzidis) and Viktor Evgenievich Petrovich (Petrovich) are
two of Belarusʼs richest oligarchs and are important ʻwalletsʼ for Lukashenka and his regime.
Topuzidis is a close confidante and has served in leadership roles on an election commission in
Minsk and as Deputy Chairman of the Belarusian Entrepreneurship Development Council.
Topuzidis, who has maintained considerable influence in Belarus, has personally funded three
ice hockey palaces, including one on one of Lukashenkaʼs personal residences. Canada has also
sanctioned Topuzidis for committing a grave breach of international peace and security.
OFAC is designating Topuzidis pursuant to E.O. 14038 for operating or having operated in the
tobacco sector of the Belarus economy. OFAC is designating Petrovich pursuant to E.O.
14038 for operating or having operated in the tobacco sector of the Belarus economy.
Through their business, Tabak Invest LLC (Tabak Invest), — which until 2017 was the only
private tobacco producer in Belarus — Topuzidis and Petrovich control 30 percent of Belarusʼs
tobacco production. According to investigative journalists in Belarus, Tabak Invest has been
heavily involved in an elaborate cigarette smuggling scheme into Russia that has generated
millions of dollars in revenue for the company.
OFAC is designating Tabak Invest pursuant to E.O. 14038 for operating or having operated in
the tobacco sector of the Belarus economy.
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B ELARUSIAN DEF ENSE SECTOR
JSC Minsk Mechanical Plant Named A er S.I. Vavilov Management Company of BelOMO
Holding (BelOMO) is a state-owned enterprise that operates in the defense sector in Belarus,
producing and selling optical sights for small arms, including telescopic sights and optical
sights with illuminated reticles. BelOMO operates as the management company for several
other defense sector entities, two of which OFAC is proposing for designation below.
OFAC is designating BelOMO pursuant to E.O. 14038 for being owned or controlled by, or
having acted or purported to act for or on behalf of, directly or indirectly, the GoB, and for
operating in the defense and related materiel sector of the Belarus economy.
Alexander Ivanovich Moroz (Moroz) is the Director General of BelOMO.
OFAC is designating Moroz pursuant to E.O. 14038 for being or having been a leader, o icial,
senior executive o icer, or member of the board of directors of BelOMO, an entity whose
property and interests in property are blocked pursuant to E.O. 14038, and for operating in the
defense and related materiel sector of the Belarus economy.
JSC Zenit BelOMO (Zenit) is owned by BelOMO, a state-owned enterprise that operates in
the defense sector in Belarus. For 50 years, Zenit has produced military sights, including
scopes with illuminated reticles, red dot sights, general purpose military sights, and spare
parts.
OFAC is designating Zenit pursuant to E.O. 14038 for being owned or controlled by, or having
acted or purported to act for or on behalf of, directly or indirectly, BelOMO, an entity whose
property and interests in property are blocked pursuant to E.O. 14038, and for operating in the
defense and related materiel sector of the Belarus economy.
Nikolai Nikolaevich Gaichuk (Gaichuk) is the Director General of Zenit.
OFAC is designating Gaichuk pursuant to E.O. 14038 for being or having been a leader, o icial,
senior executive o icer, or member of the board of directors of Zenit, an entity whose
property and interests in property are blocked pursuant to E.O. 14038, and for operating in the
defense and related materiel sector of the Belarus economy.
Scientific Technical Center LEMT BelOMO (LEMT) is owned by BelOMO, a state-owned
enterprise that operates in the defense sector in Belarus. LEMT specializes in research and
development, production, and modernization of optoelectronic and laser devices for
unmanned aerial vehicles, laser-optical systems for air defense systems, and integrated
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border security and protection systems. LEMT also produces optical sights and systems for
light armament, laser rangefinders, range-finding modules based on diode lasers, and laser
fire control systems.
OFAC is designating LEMT pursuant to E.O. 14038 for being owned or controlled by, or having
acted or purported to act for or on behalf of, directly or indirectly, BelOMO, an entity whose
property and interests in property are blocked pursuant to E.O. 14038, and for operating in the
defense and related materiel sector of the Belarus economy.
Alexei Petrovich Shkadarevich (Shkadarevich) is the Director General of LEMT.
OFAC is designating Shkadarevich pursuant to E.O. 14038 for being or having been a leader,
o icial, senior executive o icer, or member of the board of directors of LEMT, an entity whose
property and interests in property are blocked pursuant to E.O. 14038, and for operating in the
defense and related materiel sector of the Belarus economy.

SUPPORT F OR RUSSIAʼS ILLEGAL W AR EF F ORT
Open Joint Stock Company Alevkurp (Alevkurp) is a state-owned military manufacturing
company of Belarus, specializing in the creation of new radar systems. Alevkurp was
established by the Order of the President of the Republic of Belarus and is part of the State
Military Industrial Committee of the Republic of Belarus. Alevkurp was awarded by the Russian
Government for developing export-oriented military products. Alevkurp was previously
designated by the Canadian Government on November 17, 2022, pursuant to the Special
Economic Measures Act.
OFAC is designating Alevkurp pursuant to E.O. 14038 for being owned or controlled by, or
having acted or purported to act for or on behalf of, directly or indirectly, the GoB.
Planar Research and Production Holdings for Precision Engineering (Planar) is a
developer and supplier of components for microelectronics in Belarus and has experienced a
dramatic increase in demand from Russia since 2021 to replace lost imports from the
departure of foreign enterprises. In a February 2022 interview, Lukashenka said semiconductor
production will be replaced by domestic enterprises Planar, Horizont Group, and Integral. On
February 24, 2022, OFAC designated Integral pursuant to E.O. 14038 for being owned or
controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, the GoB,
as well as for operating or having operated in the defense and related materiel sector of the
Belarus economy.
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OFAC is designating Planar pursuant to E.O. 14038 for being owned or controlled by, or having
acted or purported to act for or on behalf of, directly or indirectly, the GoB.
OJSC Horizont Holding Management Company (Horizont Group) and its related
enterprises operate in the consumer and industrial electronics, plastics, and transportation
sectors in Belarus. Horizont Group is a critical player in Russiaʼs defense supply chains by
providing the Russian military with its latest generation displays. Horizont Group is an
authorized investment agent for the GoB since 2011 and produces multifunctional touch
interactive solutions for the automotive and aviation industries.
OFAC is designating Horizont Group pursuant to E.O. 14038 for being owned or controlled by,
or having acted or purported to act for or on behalf of, directly or indirectly, the GoB.

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 here.
Click here for more information on the individuals and entities sanctioned today.
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