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4/21/2022

U.S. Treasury Designates Facilitators of Russian Sanctions Evasion | U.S. Department of the Treasury

U.S. Treasury Designates Facilitators of Russian Sanctions
Evasion
April 20, 2022

Treasury Targets Financial and Operational Support Networks for Attempts to Evade U.S.,
International Sanctions
Treasury Takes New Step of Designating a Virtual Currency Mining Company
WASHINGTON – Today, the U.S. Department of the Treasuryʼs O ice of Foreign Assets Control
(OFAC) designated entities and individuals involved in attempts to evade sanctions imposed
by the United States and its international partners on Russia. OFAC designated Russian
commercial bank Transkapitalbank and a global network of more than 40 individuals and
entities led by U.S.-designated Russian oligarch Konstantin Malofeyev, including organizations
whose primary mission is to facilitate sanctions evasion for Russian entities. OFAC also
designated companies operating in Russiaʼs virtual currency mining industry, reportedly the
third largest in the world. This is the first time Treasury has designated a virtual currency
mining company.
“Treasury can and will target those who evade, attempt to evade, or aid the evasion of U.S.
sanctions against Russia, as they are helping support Putinʼs brutal war of choice,” said Under
Secretary for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will
work to ensure that the sanctions we have imposed, in close coordination with our
international partners, degrade the Kremlinʼs ability to project power and fund its invasion.”

RUSSIAN B ANK AT T HE HEART OF SANCT IONS EVASION
Public Joint Stock Company Transkapitalbank (TKB) is a Russian privately owned
commercial bank that has operated since 1992. TKB representatives have o ered services to
several banks in Asia, including within China, and the Middle East, and suggested options to
evade international sanctions. For example, to avoid detection and sanctions-derived
restrictions, TKB has o ered its clients the ability to conduct transactions via its proprietary
Internet-based banking system, known as TKB Business, an alternative communication
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channel to the Society for Worldwide Interbank Financial Telecommunication (SWIFT) network,
including for the purpose of processing U.S. dollar payments for sanctioned clients. TKB has
also sought to create a settlement hub in Asia without involving U.S. or European banks in the
clearing process.
TKB is being designated pursuant to Executive Order (E.O.) 14024 for operating or having
operated in the financial services sector of the Russian Federation economy. TKB subsidiary
Joint Stock Company Investtradebank was also designated today pursuant to E.O. 14024
for being owned or controlled by, or for having acted or purported to act for or on behalf of,
directly or indirectly, TKB. All entities owned 50 percent or more, directly or indirectly by TKB,
are subject to blocking under E.O. 14024 even if not identified by OFAC. Concurrent with this
action, OFAC issued two general licenses (GL) related to TKB, including a wind down GL
and a GL to continue for six months certain transactions

that are destined for or

originating from Afghanistan, in support of e orts to address the humanitarian crisis.

DISRUPT ING W ORLDW IDE SANCT IONS EVASION AND
MALIGN INF LUENCE
Today, OFAC also targeted a worldwide sanctions evasion and malign influence network led
by Russian oligarch Konstantin Malofeyev (Malofeyev). OFAC first designated Malofeyev in
2014 pursuant to E.O. 13660 for being responsible for or complicit in, or for having engaged in,
actions or polices that threaten the peace, security, stability, sovereignty, or territorial
integrity of Ukraine; and for having materially assisted, sponsored, or provided financial,
material, or technological support for, or goods or services to or in support of, the so-called
Donetsk Peopleʼs Republic. Malofeyev has also been sanctioned by Australia, Canada, the
European Union (EU), Japan, New Zealand, and the United Kingdom (UK).
At the time of his 2014 designation, OFAC noted that Malofeyev funded separatist activities in
Eastern Ukraine and was one of the main sources of financing for Russians promoting
separatism in Crimea. In recent years, Malofeyev, covertly or through intermediaries,
supported pro-Russian activities that undermine democracy, interfere in elections, and
degrade security and stability in a host of countries. Malofeyev served as an intermediary
between the Government of the Russian Federation (GoR) and pro-Russia politicians abroad,
facilitated funding for or directly financed pro-Russia politicians and opinion makers, and
worked to create institutions that could advance Russiaʼs interests in the European Union
from within.
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Today, OFAC designated Malofeyev pursuant to E.O. 14024 for having acted or purported to
act for or on behalf of, directly or indirectly, the GoR.
Additionally, on April 6, 2022, the U.S. Department of Justice charged Malofeyev with
conspiracy to violate U.S. sanctions and violating U.S. sanctions in connection with his hiring
of a U.S. citizen to work for him in operating television networks in Russia and Greece and
attempting to acquire a television network in Bulgaria. Malofeyev also allegedly conspired to
illegally transfer a $10 million investment he made in a U.S. bank to a business associate in
Greece.
All entities owned 50 percent or more, directly or indirectly, by Malofeyev are subject to
blocking under E.O. 14024, even if not identified by OFAC.

Malofeyevʼs Global Sanctions Evasion Network
Subject to sanctions by the U.S. and a number of other jurisdictions, Malofeyev has needed to
rely on a vast global network of cut-outs and proxies to attempt to evade sanctions and
conduct malign influence activities. Today, OFAC is taking action against that support
network.
The Autonomous Noncommercial Organization for the Study and Development of
International Cooperation in the Economic Sphere International Agency of Sovereign
Development (IASD), registered in Moscow, markets itself as a financial advisory structure
that o ers services, like debt restructuring, to African governments. In practice, IASD, in close
coordination with the GoR, pursues deals around the world to facilitate business
opportunities for sanctioned Russian companies and to enrich Malofeyev himself.
IASD was designated pursuant to E.O. 14024 for being owned or controlled by, or for having
acted or purported to act for or on behalf of, directly or indirectly, Malofeyev.
IASD is supported by an extensive sta of Russian nationals, including:
Mikhail Ilich Yakushev (Yakushev), IASDʼs chief of sta , served as an intermediary
between GoR o icials and the IASD and worked to advance IASD interests in Africa and
Asia.
Alexey Anatolyevich Subbotin (Subbotin) traveled with Malofeyev on IASD business to
Africa and conducted IASD business in Southeast Asia, in addition to participating in the
Russia-Africa Forum, in which IASD was a general partner.
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Malofeyev relied on Moldovan and Russian national Aleksandr Okulov (Okulov), a
member of IASDʼs supervisory board, who traveled to Africa as part of IASD delegations
with Malofeyev. Okulov is associated with several companies located in the Middle East.
Artem Samoylov (Samoylov), an IASD legal advisor, worked on IASDʼs behalf in Asia.
Alexey Aleksandrovich Kupriyanov (Kupriyanov) traveled with Malofeyev on IASD
business to Asia, and Nikita Melikov (Melikov) traveled to Africa and Asia on IASD
business.
OFAC designated Yakushev, Subbotin, Okulov, Samoylov, Kupriyanov, and Melikov
pursuant to E.O. 14024 for having acted or purported to act for or on behalf of, directly or
indirectly, IASD.
Four companies located in Chisinau, Moldova, were also targeted today: financial services
company Agent de Asigurare Lider Asig Societate cu Raspundere Limitata (Lider Asig);
financial company Organizatia de Creditare Nebancara Lider Leasing SRL (Lider Leasing);
OKAF Trading Societatea cu Raspundere Limitata (OKAF Trading), which operates in a
number of fields, including the provision of civil and non-o ensive military equipment; and
property services company Societatea cu Raspundere Limitata Project Invest Company
(Project Invest).
Lider Asig, Lider Leasing, OKAF Trading, and Project Invest were designated pursuant to
E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on
behalf of, directly or indirectly, Okulov.
IASDʼs business is not just limited to Africa and Asia. A Singapore-based management
consultancy, MGI PTE Ltd, facilitated IASDʼs activities in Cuba. MGI PTE Ltd was designated
pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to
act for or on behalf of, directly or indirectly, IASD.
Joint Stock Company Marshal.Global (MarGlo) is a Moscow-based financial company linked
to a number of Malofeyev associates. MarGloʼs mission is to provide a wide range of financial
services for or on behalf of sanctioned Russian companies that would allow those firms to
evade sanctions.
MarGlo was designated pursuant to E.O. 14024 for operating or having operated in the
financial services sector of the Russian Federation economy, and also for being responsible for
or complicit in, or for having directly or indirectly engaged or attempted to engage in,
deceptive or structured transactions or dealings to circumvent any United States sanctions,
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including through the use of digital currencies or assets or the use of physical assets, for or
on behalf of, or for the benefit of, directly or indirectly, the GoR.
Russian national Mikhail Aleksandrovich Leshchenko, MarGloʼs general director, was
designated 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 MarGlo.

Malofeyevʼs Malign Influence Ecosystem
Russia-based company Tsargrad OOO (Tsargrad) is a cornerstone of Malofeyevʼs broad
malign influence network. Tsargrad spreads pro-Kremlin propaganda and disinformation that
is amplified by the GoR. Tsargrad served as an intermediary organization between pro-Russian
European politicians and GoR o icials, and recently pledged to donate more than $10 million
to support Russiaʼs unprovoked war against Ukraine.
Tsargrad was designated pursuant to E.O. 14024 for being owned or controlled by, or for
having acted or purported to act for or on behalf of, directly or indirectly, Malofeyev.
Russian national Pavel Vladimirovich Kuzmin (Kuzmin) provided legal services to Malofeyev
in multiple capacities, including as IASDʼs legal chief and the director of legal services at
Tsargrad. Kuzmin was designated 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, Malofeyev, and also for being or having been a leader, o icial, senior
executive o icer, or member of the board of directors of Tsargrad.
Analiticheski Tsentr Katekhon OOO (Katekhon), located in Moscow, presents itself as a
think tank but is in fact a proliferator of anti-Western and pro-Kremlin disinformation and
propaganda that clearly targets fringe audiences in the West. Katekhon actively disseminates
disinformation meant to undermine Western solidarity as well as a variety of conspiracy
theories, some of which are anti-Catholic or anti-Semitic. In recent months Katekhon has
published extreme anti-Ukraine content, including articles that recommend di erent ways to
divide Ukraineʼs territory, suggest Russian military control is the only way to save Ukraine, and
falsely claim the Government of Ukraine (GoU) is developing biological weapons and has
perpetrated a systemic genocide against residents of the Donbas region.
Katekhon was designated pursuant to E.O. 14024 for being owned or controlled by, or for
having acted or purported to act for or on behalf of, directly or indirectly, Tsargrad.

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Yakushev, the IASD chief of sta , is also Katekhonʼs general director. He was additionally
designated 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 Katekhon.
The anti-Ukraine language endorsed by Tsargrad and Katekhon is typical for Malofeyev, who
recently called the GoU “demoniac clowns” and advocated for Russians to rally around
President Vladimir Putin in support of Russiaʼs further invasion of Ukraine. That rhetoric is also
promoted and propagated by the All-Russian Public Organization Society for the
Promotion of Russian Historical Development Tsargrad (Tsargrad Society), a Russiaregistered organization which has been accused of involvement in espionage on behalf of
Russia. Tsargrad Society, formerly known as the Double-Headed Eagle Society, advocates for
Russia to return to a monarchical system of government and counts among its core principles
revanchist aims like the “reunification of the Russian people” and “returning the Russian
Empire to its historical borders”—to include, in Tsargrad Societyʼs opinion, Ukraine, Belarus,
the Baltic States, Moldova, Central Asia, and the Caucasus.
OFAC designated the Tsargrad Society pursuant to E.O. 14024 for being owned or controlled
by, or for having acted or purported to act for or on behalf of, directly or indirectly, Malofeyev.
A number of other mostly Russia-based companies, many of which are registered at the same
addresses, are part of Malofeyevʼs Tsargrad network:
Teshilovo OOO and Spetsinvestservis OOO (Spetsinvestservis) were designated
pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported
to act for or on behalf of, directly or indirectly, Malofeyev.
Imenie Tsargrad OOO (Imenie), Tsargrad-Media OOO (Tsargrad-Media), and Russiaoccupied Crimea-based Kurort Livadiya OOO were designated pursuant to E.O. 14024 for
being owned or controlled by, or for having acted or purported to act for or on behalf of,
directly or indirectly, Tsargrad.
Tsargrad Park OOO (Tsargrad Park), Kurort Tsargrad Spas-Teshilovo OOO, ZarecheOka OOO, Proizvodstvenno-Stroitelnaya Kompaniya SNM, Imperiya 19-31 OOO
(Imperiya), and Ekoferma Zareche OOO were designated pursuant to E.O. 14024 for
being owned or controlled by, or for having acted or purported to act for or on behalf of,
directly or indirectly, Imenie.
Tsargrad-Kultura OOO was designated pursuant to E.O. 14024 for being owned or
controlled by, or for having acted or purported to act for or on behalf of, directly or
indirectly, Tsargrad-Media.
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Kontur OOO and Tureya OOO were designated pursuant to E.O. 14024 for being owned
or controlled by, or for having acted or purported to act for or on behalf of, directly or
indirectly, Imperiya.
The above firms are led by Russian nationals, including Spetsinvestervis general director
Yevgeniy Yuryevich Gadetskiy (Gadetskiy), MarGlo-a iliated Imperiya general director
Roman Viktorovich Nechiporuk (Nechiporuk), and Tsargrad-Media and Tsargrad Park
general director Natalya Aleksandrovna Tyurina (Tyurina).
Gadetskiy was designated 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 Spetsinvestservis. Nechiporuk
was designated 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 Imperiya. Tyurina was designated
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 Tsargrad-Media and Tsargrad Park.

Malofevevʼs Family
Russian national Kirill Konstantinovich Malofeyev (Kirill) is Malofeyevʼs son and owns
several Russia-based companies, including Limited Liability Company Vladeks Kholding
(Vladeks Kholding), Limited Liability Company Vladeks (Vladeks), and Limited Liability
Company Russian Digital Solutions (Rus.Digital). Malofeyev was involved in the creation of
Vladeks, which was intended to be a cryptocurrency exchange project.
Kirill was designated pursuant to E.O. 14024 for operating or having operated in the
technology sector of the Russian Federation economy. Vladeks Kholding, Vladeks, and
Rus.Digital were designated pursuant to E.O. 14024 for being owned or controlled by, or for
having acted or purported to act for or on behalf of, directly or indirectly, Kirill.
Russian national Ilya Anatolyevich Markov (Markov) is the general director of Vladeks
Kholding. Markov was designated 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 Vladeks Kholding.

TARGET ING RUSSIAʼS VIRT UAL CURRENCY MINING
INDUST RY
Treasury is also taking action against companies in Russiaʼs virtual currency mining industry.
By operating vast server farms that sell virtual currency mining capacity internationally, these
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companies help Russia monetize its natural resources. Russia has a comparative advantage in
crypto mining due to energy resources and a cold climate. However, mining companies rely on
imported computer equipment and fiat payments, which makes them vulnerable to sanctions.
The United States is committed to ensuring that no asset, no matter how complex, becomes
a mechanism for the Putin regime to o set the impact of sanctions.
Virtual currency mining company Bitriver was founded in Russia in 2017 and currently operates
out of three o ices across Russia. In 2021, Bitriver shi ed legal ownership of its assets to a
Switzerland-based holding company. OFAC designated this holding company, Bitriver AG,
pursuant to E.O. 14024 for operating or having operated in the technology sector of the
Russian Federation economy.
OFAC additionally designated 10 Russia-based subsidiaries of Bitriver AG pursuant to E.O.
14024 for being owned or controlled by, or for having acted or purported to act for or on
behalf of, directly or indirectly, Bitriver AG: OOO Management Company Bitriver, OOO
Bitriver Rus, OOO Everest Grup, OOO Siberskie Mineraly, OOO Tuvaasbest, OOO Torgovy
Dom Asbest, OOO Bitriver-B, OOO Bitriver-K, OOO Bitriver-North, and OOO BitriverTurma.

STAT E DEPART MENT VISA ACT IONS
These sanctions are coordinated with further action taken today by the Department of State.
The United States is imposing visa restrictions on 635 Russian nationals who are involved in
suppressing dissent in Russia and abroad, who have been involved in activities that threaten
the territorial integrity of Ukraine, and who have been involved in human rights abuses in
prison facilities and places of uno icial detention in Russia-controlled areas of the Donbas
region of Ukraine. Further, the Department of State is imposing visa restrictions on three
Russian Federation o icials for involvement in gross violations of human rights, and on 17
individuals responsible for undermining democracy in Belarus. For further information on
these actions, please see the o icial State Department statement.

SANCT IONS IMPLICAT IONS
As a result of todayʼs action, all property and interests in property of the persons 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, 50 percent
or more by one or more blocked persons are also blocked. All transactions by U.S. persons or
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within (or transiting) the United States that involve any property or interests in property of
designated or otherwise blocked persons are prohibited unless authorized by a general or
specific license issued by OFAC, or exempt. These prohibitions include the making of any
contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked
person and the receipt of any contribution or provision of funds, goods, or services from any
such person.
For identifying information on the individuals and entities sanctioned today, click here.
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