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9/14/2023

With Wide-Ranging New Sanctions, Treasury Targets Russian Military-Linked Elites and Industrial Base | U.S. Departme…

With Wide-Ranging New Sanctions, Treasury Targets Russian
Military-Linked Elites and Industrial Base
September 14, 2023

WASHINGTON — Today, the U.S. Department of the Treasuryʼs O ice of Foreign Assets
Control (OFAC) is imposing nearly 100 sanctions on Russian elites and Russiaʼs industrial base,
financial institutions, and technology suppliers as the United States continues to leverage
sanctions and economic restrictions to undermine Russiaʼs capacity to wage its war against
Ukraine. The Department of State also designated more than 70 persons. Todayʼs sanctions
focus on persons benefiting from, supporting, and sustaining Russiaʼs brutal war of choice
against Ukraine.
“With todayʼs sanctions, the United States is continuing our relentless work to target Russiaʼs
military supply chains and deprive Putin of the equipment, technology, and services he needs
to wage his barbaric war on Ukraine,” said Secretary of the Treasury Janet L. Yellen. “We have
also made clear that those individuals and entities who profit from invasion and their
proximity to the Kremlin will be held accountable, and todayʼs actions show our global reach in
imposing severe costs on Putinʼs oligarchs.”

IMPOSING COSTS ON RUSSIAʼS W AR PROF IT EERS
On August 11, 2023, Deputy Secretary Adeyemo said that “wealthy Russian elites should
disabuse themselves of the notion that they can operate business as usual while the Kremlin
wages war against the Ukrainian people.” Today, OFAC continues its e orts to target Russian
elites and firms that benefit from their ties to Russiaʼs defense sector, military-industrial
complex, and a iliation with the Kremlin.
Today, OFAC designated Russian oligarch Andrei Removich Bokarev (Bokarev), Bokarevʼs
wife Olga Vladimirovna Syrovatskaya (Syrovatskaya), and major Russian rolling stock
manufacturer Transmashholding JSC (Transmash). Bokarev served as President of
Transmash and owns or serves on the board of other Russia-based rail-related manufacturing
firms. Bokarev is also a board member of the U.S.-designated Russian Association of
Employers the Russian Union of Industrialists and Entrepreneurs (RSPP).
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In addition, Bokarev has personal ties to Russian Defense Minister Sergei Shoigu and other
senior Kremlin o icials and their families. Bokarev is also linked to organized crime and since
2022 has sought to evade sanctions. Since 2022, Bokarev has worked with assorted Trust and
Corporate Service Providers to create shell companies, behavior that can be associated with
money laundering. Bokarev has also been sanctioned by Australia, New Zealand, and the
United Kingdom (UK).
In 2022, Russian o icials engaged Transmash to produce parts for infantry combat vehicles.
The U.S. Department of State designated Transmash subsidiary Metrovagonmash Joint Stock
Company on May 19, 2023 pursuant to Executive Order (E.O.) 14024 and noted its involvement
in the production of military equipment, including chassis a ixed to Russian surface-to-air
radar, weapons systems, and multiple variants of armored tracked vehicles.
Bokarev and Transmash were designated pursuant to E.O. 14024 for operating or having
operated in the manufacturing sector of the Russian Federation economy. Bokarev was also
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 the RSPP, a person whose property and
interests in property are blocked pursuant to E.O. 14024. Syrovatskaya was designated
pursuant to E.O 14024 for being a spouse or adult child of Bokarev.
OFAC also designated Bokarevʼs business partner and fellow tycoon Iskandar
Kakhramonovich Makhmudov (Makhmudov) and Makhmudovʼs son Dzhakhangir
Iskandarovich Makhmudov (Dzhakhangir). Makhmudov, who founded and owned U.S.designated Joint Stock Company Ural Mining and Metallurgical Company (UMMC), owns or sits
on the board of other Russia-based metals and mining companies, and owns several Russiabased financial services entities. Makhmudov also has links to Russian organized crime.
Dzhakhangir is a UMMC o icial and previously worked for a zinc plant in Russia. Makhmudov
has also been sanctioned by New Zealand and the UK.
Makhmudov and Dzhakhangir were designated pursuant to E.O. 14024 for operating or having
operated in the metals and mining sector of the Russian Federation economy. Makhmudov
was also designated pursuant to E.O. 14024 for operating or having operated in the financial
services sector of the Russian Federation economy.
Open Joint Stock Company Aero Engine Scientific and Technical Complex Soyuz (Soyuz)
is a Russia-based business involved in Russiaʼs military aerospace industry, including building
engines for cruise missiles and military transport aircra .
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Open Joint Stock Company Balashikhinskiy Liteyno Mekhanicheskiy Zavod (Balashikha)
is a Russia-based company involved in the manufacture, development, production, testing,
and repair of aviation equipment. Russia's Ministry of Defense is a main consumer of
Balashikha's products.
Soyuz and Balashikha were designated pursuant to E.O. 14024 for operating or having
operated in the aerospace sector of the Russian Federation economy.
Russian national Mkrtich Okroevich Okroyan (Mkrtich) is the Soyuz chief designer and a
member of Balashikhaʼs board of directors. Mkrtichʼs wife is Alla Fedorovna Baban (Baban).
Mkrtichʼs children, Anna Mkrtichevna Okroyan (Anna) and Andranik Mkrtichovich
Okroyan (Andranik), are members of the Soyuz board of directors, along with Mkrtichʼs
brother, Arutyun Okroevich Okroyan (Arutyun).
Mkrtich 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 Soyuz and Balashikha as well
as for operating or having operated in the aerospace sector of the Russian Federation
economy.
Baban was designated pursuant to E.O. 14024 for being a spouse or adult child of Mkrtich.
Anna and Andranik were designated pursuant to E.O. 14024 for being spouses or adult
children of Mkrtich as well as for operating or having operated in the aerospace sector of the
Russian Federation economy. Arutyun was designated pursuant to E.O. 14024 for operating or
having operated in the aerospace sector of the Russian Federation economy.
Aleksei Yurievich Krivoruchko (Krivoruchko) has served as a Russian Deputy Defense
Minister since 2018. Krivoruchko, a former CEO of U.S.-designated Joint Stock Company
Concern Kalashnikov, was previously designated pursuant to E.O. 13661 for being an o icial of
the Government of the Russian Federation and pursuant to E.O. 14024 for operating or having
operated in the defense and related materiel sector of the Russian Federation economy.
Krivoruchko is also sanctioned by Australia, Canada, the European Union (EU), Japan, New
Zealand, and the UK.
Krivoruchko was designated today 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 the Government of the
Russian Federation. OFAC also designated Krivoruchkoʼs wife, Ekaterina Vladimirovna
Krivoruchko (Ekaterina). Ekaterina was designated pursuant to E.O. 14024 for being a spouse
or adult child of Krivoruchko.
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OFAC also designated additional Russia-based entities that directly contribute to Russiaʼs war
against Ukraine by virtue of their production of military materiel:
Joint Stock Company Gavrilov Yam Machine Building Plant Agat (Agat) manufactures
aircra engines, including engines for unmanned aerial vehicles (UAVs).
Joint Stock Company Star (JSC Star), which is part of U.S.-designated, Russian state-owned
defense conglomerate State Corporation Rostec (Rostec), develops and manufactures aircra
engines. Rostec was designated pursuant to E.O. 14024 and is subject to Directive 3 under
E.O. 13662.
Joint Stock Company Mechanical Engineering Research Institute (NIMI) is a producer of
weapons and ammunition for government weapons programs.
Aktsionernoe Obshchestvo Ulyanovskii Patronnyi Zavod (Ulyanovsk Cartridge Works) is an
ammunition manufacturer.
Agat and JSC Star were designated pursuant to E.O. 14024 for operating or having operated
in the manufacturing sector of the Russian Federation economy.
NIMI and Ulyanovsk Cartridge Works were designated pursuant to E.O. 14024 for operating or
having operated in the defense and related materiel sector of the Russian Federation
economy.

DISRUPT ING RUSSIAʼS T ECHNOLOGY SUPPLY CHAINS
The combined e orts of the United States, alongside our Allies and partners, continue to limit
Russiaʼs ability to acquire, develop, and maintain technology needed by its war machine.
Todayʼs actions continue OFACʼs sustained e orts to target individuals and entities that
enable—or attempt to enable—Russiaʼs ability to procure high-tech and dual-use goods.

Siberica and Luminor Network
Today, OFAC is designating a Finland-based network that specializes in shipping foreign
electronics to Russia-based end-users. Finland-based logistics firms Siberica Oy (Siberica)
and Luminor Oy (Luminor) have sent a wide variety of electronics into Russia, including UAV
cameras, high-performance optical filters, and lithium batteries. French national Gabriel
Temin is Sibericaʼs owner, managing director, and a member of Sibericaʼs board of directors
and Estonian national Catherine Esther Temin is a deputy board member of Siberica. OFACʼs
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action was the result of close and ongoing collaboration with Homeland Security
Investigations (HSI), Atlanta Field Division.
Siberica, Luminor, and Gabriel Temin were designated pursuant to E.O. 14024 for operating or
having operated in the electronics sector of the Russian Federation economy. Luminor was
also 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, Gabriel Temin. Gabriel Temin and
Catherine Esther Temin were designated pursuant to E.O. 14024 for being or having been
leaders, o icials, senior executive o icers, or members of the board of directors of Siberica.
The following Russia-based entities were importing directly from Luminor:
Flytechgroup Limited Liability Company (Flytechgroup) is a Russia-based supplier of
products and materials for aviation, technical, and industrial purposes for airlines, railway
transport, and enterprises of Russiaʼs military-industrial complex. Flytechgroup was
designated pursuant to E.O. 14024 for operating or having operated in the aerospace
sector of the Russian Federation economy.
OOO NPK Fotonika Limited Liability Company (NPK Fotonika) is a Russia-based
company specializing in development of digital optical systems, with clients in the
defense, mining, and railway sectors. NPK Fotonika was designated pursuant to
E.O. 14024 for operating or having operated in the electronics sector of the Russian
Federation economy.
Globaltrans Limited (Globaltrans) and Limited Liability Company Aservice (Aservice)
are Russia-based companies o ering freight transportation services. Globaltrans and
Aservice were designated pursuant to E.O. 14024 for operating or having operated in the
transportation sector of the Russian Federation economy.
OOO Mayak (Mayak) is a Russia-based wholesaler of computers, so ware, machinery, and
industrial equipment. Mayak was designated pursuant to E.O. 14024 for operating or
having operated in the technology sector of the Russian Federation economy.

Türkiye-based Companies
Russia continues to rely on third-country entities to keep importing much-needed dual-use
goods to enable its unprovoked war of aggression on Ukraine. The U.S. Department of the
Treasury has repeatedly raised the issue of the shipment or transshipment of dual-use goods
to Russia with the Government of Türkiye and the Turkish private sector. Today, OFAC is
targeting two entities based in Türkiye.
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Margiana Insaat Dis Ticaret Limited Sirketi (Margiana) has made hundreds of shipments to
Russia-based entities Limited Liability Company SMT-iLogic (SMT-iLogic) and Saturn EK OOO
(Saturn EK), which were designated pursuant to E.O. 14024 on May 19, 2023 and July 20, 2023,
respectively. SMT-iLogic is known to be involved in the supply chain for producing Russian
military UAVs used in Russiaʼs war against Ukraine. Margianaʼs shipments to SMT-iLogic and
Saturn EK have included High Priority Items

of the kind recovered in multiple Russian

weapons systems used against Ukraine, including the Kalibr cruise missile, the Kh-101 cruise
missile, and the Orlan-10 UAV.
Margiana 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, SMT-iLogic and Saturn EK, persons whose property and interests in property are blocked
pursuant to E.O. 14024.
Demirci Bilisim Ticaret Sanayi Limited Sirketi (Demirci), founded in March 2022, has sent
sensors and measuring tools into Russia.
Demirci was designated pursuant to E.O. 14024 for operating or having operated in the
technology sector of the Russian Federation economy.

AK Microtech-Related Persons
On July 20, 2023, OFAC designated Russia-based entity Limited Liability Company AK
Microtech (AKM) pursuant to E.O. 14024 for operating or having operated in the electronics
sector of the Russian Federation economy. AKM specializes in transferring foreign
semiconductor technology to Russian microelectronics production companies, including
entities that provide microelectronics to the Russian defense industry.
Today, OFAC designated AKMʼs owner and director, Russian national Andrei Rostislavovich
Khokhlun (Khokhlun), as well as two companies owned by Khokhlun: Russia-based Limited
Liability Company Keko R (Keko R) and Slovenia-based Arktec Tehnologije na Podrocju
Elektronike doo (Arktec).
Khokhlun was designated pursuant to E.O. 14024 for operating or having operated in the
electronics sector of the Russian Federation economy. Keko R and Arktec 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, Khokhlun.

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Russian Electronics and Technology Companies
The following Russia-based entities were designated pursuant to E.O. 14024 for operating or
having operated in the electronics sector of the Russian Federation economy:
OOO Enkor Grupp is a manufacturer of diodes, transistors, and other semiconductor
devices.
Nauchno Proizvodstvennoe Predpiyatie Itelma is a leading Russian developer and
manufacturer of electronic solutions for vehicles as well as a prolific importer of dual-use
microchips.
OOO Makro Grupp is a provider of electronic components to Russiaʼs aerospace and
aviation sectors.
Limited Liability Company Streloi is a wholesaler of electronic equipment and parts.
Vertikal Limited (Vertikal) is a wholesaler of electronic equipment, computers, so ware,
and measuring instruments. Ilya Andreevich Buzin (Buzin) is the General Director of
Vertikal. Buzin was also designated pursuant E.O. 14024 for being or having been a leader,
o icial, senior executive o icer, or member of the board of directors of Vertikal.
OOO VMK (VMK) is a supplier of electronic products, including circuit boards, wires,
connectors, and microchips. VMK, one of the largest Russian importers of dual-use
microchips, supplies electronics to U.S.-designated Joint Stock Company Concern RadioElectronic Technologies, a subsidiary of Rostec that develops electronic warfare systems
for the Russian military.
The following Russia-based entities were designated pursuant to E.O. 14024 for operating or
having operated in the technology sector of the Russian Federation economy:
OOO Aiti Tsentr is a wholesaler of electronics, computers, and so ware.
Limited Liability Company Baltinfokom manufactures computer equipment, cloud
storage processing systems, and specialized so ware.
OOO Bitteriya supplies IT equipment and so ware.
Eastern Trade Limited Liability Company manufactures computers, data storage
device, and information security equipment.
Joint Stock Company Echelon Union for Science and Development is a systems
integrator in the field of information security and is licensed by the U.S.-designated

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Russian Federal Security Service (FSB) as well as the Federal Service on Technical and
Export Control of Russia and the Russian Ministry of Defense.
Limited Liability Company Inforion is a systems integrator that provides services and
solutions in the areas of information security, import substitution, research and design of
microelectronics, IT and management consulting, big data, and reverse engineering of
so ware and hardware.
Obshchestvos Ogranichennoi Otvetstvennostyu Inforser Inzhiniring is an information
technology company that provides digital transformation services and that designs and
constructs specialized facilities.
Intech Engineering LTD is a wholesaler of computers and so ware.
Joint Stock Company Kra way Corporation PLS (Kra way) develops information
security so ware and hardware systems. On December 8, 2022, the Department of
Commerceʼs Bureau of Industry and Security added Kra way to the Entity List for
Kra wayʼs significant contributions to or their involvement in the Russian military and/or
the defense industrial base.
Limited Liability Company Kvarta VK is an information technology systems integration
company that provides custom computer programming services.
OOO Lanprint is an IT company specializing in the wholesale of computers, o ice
equipment, processors, servers, network equipment, and microelectronics.
OOO Novyi Ai Ti Proekt is a manufacturer of computers, memory devices, and
information security equipment.
Aktsionernoe Obshchestvo Pluton is a research and production complex engaged in the
development and production of modern electrovacuum devices, including with military
applications.
Federal State Unitary Enterprise Rostov on Don Research Institute of Radio
Communicationsʼs (RNIIRS) business includes security and IT systems and hardware and
so ware solutions. RNIIRS is also involved in the production of military UAVs.
Joint Stock Company Signaltek produces network security and satellite equipment.
Silkway Limited Liability Company is wholesaler of computers, so ware, machinery,
and IT equipment.
OOO Solar Sekyuriti (Solar Security) provides threat analysis and intrusion prevention
and builds and operates cybersecurity systems. Solar Security holds a license from the
FSB for the development, production, and distribution of encryption services.
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Limited Liability Company Status Complains provides computer system design
services.
Svetlana Rost Joint Stock Company (Svetlana Rost) is a full-cycle semiconductor
enterprise. Svetlana Rost has a Russia-based subsidiary, Obshchestvo S Ogranichennoi
Otvetstvennostyu Rost Progress (Rost Progress). Rost Progress 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, Svetlana Rost.
Joint Stock Company Special Economic Zone Technopolis Moscow (Technopolis
Moscow) manages a special economic zone that fosters the development of high-tech
companies and specializes in micro- and nanoelectronics and robotics. Technopolis
Moscow is home to an industrial park that will host companies producing UAVs.
OOO Trialkom is a wholesaler of electronics, computers, and so ware.
Limited Liability Company Tribit provides digital hardware design, consulting, and
so ware development services.
OOO Vneshekostil is one of the largest importers of dual-use chips into Russia.
Aktsionernoe Obshchestvo Taskom is a Russia-based company involved in freight transport
by road and transportation services, and the storage of goods. Taskom was designated
pursuant to E.O. 14024 for operating or having operated in the transportation sector of the
Russian Federation economy.

TARGET ING RUSSIAʼS INDUST RIAL B ASE AND
CONST RUCT ION SECTOR
On May 19, 2023, G7 Leaders committed to target those operating in Russiaʼs manufacturing
and construction sectors. Today, OFAC underscores that commitment by sanctioning a
number of leading Russian manufacturing and construction firms.
The following Russia-based entities were designated pursuant to E.O. 14024 for operating or
having operated in the manufacturing sector of the Russian Federation economy:
Joint Stock Company Avtovaz is an automotive manufacturer.
Gaz Group is an automotive manufacturer. Gaz Group was previously designated
pursuant to E.O. 13661 and E.O. 13662 for being owned or controlled by, or having acted
or purported to act for or on behalf of, directly or indirectly, Oleg Vladimirovich Deripaska

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and Russian Machines, persons whose property and interests in property are blocked
pursuant to E.O. 13661 and E.O. 13662. Gaz Group is also sanctioned by Japan.
Joint Stock Company HMS Group manufactures industrial pumps and compressors.
Kirovsky Zavod Public Joint Stock Company produces machinery and steel products
for a variety of industries.
Kriogenmash OAO (Kriogenmash) manufactures equipment for producing, processing,
transporting, and storing industrial gases. Kriogenmash is also subject to Directive 1
under E.O. 13662.
Joint Stock Company Moscow Automotive Factory Moskvich is an automotive
manufacturer.
JSC Power Machines (Power Machines) is a manufacturer of turbines and electrical
equipment for power plants and industry. Power Machines was previously designated
pursuant to E.O. 13685 for having materially assisted, sponsored, or provided financial,
material, or technological support for, or goods or services to OAO Technopromexport
and Technopromexport LLC, persons whose property and interests in property are blocked
pursuant to E.O. 13685. Power Machines is also sanctioned by Canada.
Publichnoe Aktsionernoe Obschestvo Sollers is an automotive manufacturer.
Limited Liability Company Machine Building Plant Tonar is an automotive
manufacturer.
Joint Stock Company United Metallurgical Company (OMK) is a manufacturer of steel
pipes and other steel products. OMK is also sanctioned by the UK.
Open Joint Stock Company Tikhoretsk Machine Construction Plant V.V.
Vorovsky manufactures railway machinery.
The following Russia-based entities were designated pursuant to E.O. 14024 for operating or
having operated in the construction sector of the Russian Federation economy:
Aktsionernoe Obshchestvo Mosinzhproekt is a civil engineering and construction
company active in construction projects located in Moscow.
Russian Highways State Company is a construction and engineering company primarily
involved in the construction of motorways and related infrastructure.
Transstroimekhanizatsiya Limited Liability Company is a construction company
involved in industrial and transportation construction projects.

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F URT HER LIMIT ING RUSSIAʼS REVENUE F ROM
EXT RACT IVES AND F UT URE EXT RACT IVES CAPAB ILIT IES
Todayʼs action also cuts into Russiaʼs revenue streams from extractive industries, including
targeting entities that will contribute to Russiaʼs future energy revenues.
Aktsionernoe Obshchestvo BashVzryvTekhnologii (BVT) is a Russia-based company that
manufactures perforation systems and detonation equipment for oil and gas exploration. BVT
was designated pursuant to E.O. 14024 for operating or having operated in the manufacturing
sector of the Russian Federation economy.
Limited Liability Company Gazprom Nedra (Gazprom Nedra) is a Russia-based company
that provides engineering services for oil and gas exploration. Gazprom Nedra was
designated pursuant to E.O. 14024 for operating or having operated in the engineering sector
of the Russian Federation economy.
Joint Stock Company Gazstroyprom (Gazstroyprom) and Velesstroi Limited Liability
Company (Velesstroi) are Russia-based construction companies involved in energy-related
construction projects. Gazstroyprom and Velesstroi were designated pursuant to E.O. 14024
for operating or having operated in the construction sector of the Russian Federation
economy.
JSC AGD Diamonds (AGD Diamonds) is a Russia-based company involved in the prospecting,
exploration, production, mining, and the processing of minerals. Grib Diamonds is AGD
Diamondsʼ Belgium-based subsidiary.
AGD Diamonds was designated pursuant to E.O. 14024 for operating in or having operated in
the metals and mining sector of the Russian Federation economy. Grib Diamonds 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, AGD Diamonds.
On June 27, 2023, six agencies of the U.S. government issued a business risk advisory related
to the sub-Saharan African gold sector, which discussed, among other things, concerns
related to Wagnerʼs exploitation and profiteering from gold in Mali and other countries.
Vitalij Victorovich Perfilev (Perfilev), a Russian national, is a Wagner Group o icial in CAR
serving as the national security advisor to the CAR President. Perfilev has been responsible
for dra ing communiques to the CAR armed forces senior leadership regarding rebel forcesʼ
activities. The European Union also sanctioned Perfilev in June 2023.
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OFAC designated Perfilev 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, the Wagner Group, a
person whose property and interests in property are blocked under E.O.14024.

CURTAILING RUSSIAʼS ACCESS TO T HE INT ERNAT IONAL
F INANCIAL SYST EM
To continue restricting Russiaʼs ability to benefit from connections to the international
financial system, OFAC is designating two more Russia-based banks as well as several Russiabased wealth management consulting, auditing, and investment firms.
Joint Stock Commercial Bank Ak Bars Public Joint Stock Company (Ak Bars Bank) is a
commercial financial institution located in Kazan, Russia.
Obshchestvo s Ogranichennoi Otvetstvennostyu Kommercheski Bank Sinko Bank (Sinko
Bank) is a regional bank located in Moscow, Russia.
Ak Bars Bank and Sinko Bank were designated pursuant to E.O. 14024 for operating or having
operated in the financial services sector of the Russian Federation economy.
Katarzyna Ewa Pawlowska Hanafin (Pawlowska), a Polish national, is the chief operating
o icer of Huriya Private FZE LLE (Huriya) and the wife of U.S.-designated John Desmond
Hanafin (Hanafin), the chief executive o icer of Huriya. Huriya and Hanafin were designated
on May 19, 2023 pursuant to E.O. 14024 for operating or having operated in the financial
services sector of the Russinn Federation economy. Hanafin was also 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 Huriya. Huriya is a private equity and corporate structuring entity heavily
involved in moving Russian finance into and through the UAE financial sector, and money
laundering. Since Russiaʼs full-scale invasion of Ukraine in 2022, Huriya began working quickly
to move Russian assets into structures protecting them from sanctions. Huriya also helped
high-net-worth Russian nationals procure non-Russian passports under assumed names to
avoid financial scrutiny and sanctions.
Pawlowska was designated pursuant to E.O. 14024 for operating or having operated in the
financial services sector of the Russian Federation economy; for being or having been a leader,
o icial, senior executive o icer, or member of the board of directors of Huriya, a person
whose property and interests in property are blocked pursuant to E.O. 14024; and for being a
spouse or adult child of Hanafin.
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Obshchestvo S Ogranichennoi Otvetstvennostyu A1 (A1) is a Russia-based investment
company involved in asset management, debt collection, and bankruptcy services, and
Obshchestvo S Ogranichennoi Otvetstvennostyu Investitsionnaya Kompaniya
A1 (Investment Company A1) is a Russia-based investment company involved in asset
management and credit provisioning. A1 and Investment Company A1 are investment
businesses of Alfa Group, a Russia-based entity connected to U.S.-designated individuals Petr
Olegovich Aven, Mikhail Maratovich Fridman, German Borisovich Khan, and Alexey Viktorovich
Kuzmichev.
A1 and Investment Company A1 were designated pursuant to E.O. 14024 for operating or
having operated in the financial services sector of the Russian Federation economy.
KSK Group (KSK) is a Russia-based business consulting company that provides clients a
variety of financial services. OOO KSK Audit is a Russia-based company o ering consulting
services for financial audits, accounting, taxes, and commercial management. Russian national
Aleksey Sergeyevich Chubarov (Chubarov) is the Head of International Structuring at KSK.
KSK and Chubarov were designated pursuant to E.O. 14024 for operating or having operated
in the financial services sector of the Russian Federation economy. OOO KSK Audit was
designated pursuant to E.O. 14024 for operating or having operated in the accounting sector
of the Russian Federation economy.

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
within (or transiting) the United States that involve any property or interests in property of
designated or 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.
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
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With Wide-Ranging New Sanctions, Treasury Targets Russian Military-Linked Elites and Industrial Base | U.S. Departme…

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.
For identifying information on the individuals and entities sanctioned today, click here.
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