US sanctions 22 Russians over ‘malign activities’ & 12 added to Section 231 CAATSA list

OFAC2

Yesterday (19 December), OFAC sanctioned 18 Russian nationals and 4 Russia-based entities in response to “Russia’s continued disregard for international norms”:

(i) Victor Alekseyevich Boyarkin, a former officer of Russia’s Main Intelligence Directorate (GRU), was designated pursuant to Executive Orders (EO) 13661 and 13662 (asset freeze and travel ban) for acting on behalf of sanctioned oligarch Oleg Deripaska.

(ii) Alexander Aleksandrovich Malkevich and Elena Alekseevna Khusyaynova, as well as the entities Nevskiy News LLC, Economy Today LLC, Federal News Agency LLC and USA Really were designated pursuant to EO 13694 (asset freeze and travel ban) for being linked to Project Lakhta– a broad Russian effort that includes the previously designated Internet Research Agency (IRA), which has sought to “interfere in political and electoral systems worldwide”.

(iii) 15 members of the GRU were designated under Section 224 of CAATSA (asset freeze and travel ban) for their “involvement in a wide range of malign activity”, including attempting to interfere in the 2016 US election, efforts to undermine international organisations (e.g. WADA and OPCW) through cyber-enabled means, and carrying out the Novichok assassination attempt against the Skripals in Salisbury, UK. See OFAC Notice and US Treasury Press Release.

The US Department of State has also added 12 individuals and entities from the present OFAC action to the List of Specified Persons under Section 231 of CAATSA for being part of, or operating for or on behalf of, the intelligence sector of the Russian government. As a result, any person who knowingly engages in a significant transaction with any of these 12 individuals and entities will be subject to CAATSA Section 231 sanctions. See State Department Press Release.

This entry was posted in Russia, USA by Michael O'Kane. Bookmark the permalink.

About Michael O'Kane

Michael O’Kane is a partner and Head of the Business Crime team at leading UK firm Peters & Peters. Described as ‘first-rate’ (Legal 500 2012), he “draws glowing praise from commentators” (Chambers 2013) for handling the international aspects of business crime, including sanctions, extradition and mutual legal assistance. Called to the Bar in 1992 and prior to joining Peters & Peters he was a senior specialist prosecutor at the Crown Prosecution Service Headquarters(CPS). At CPS HQ he was a key member of a small specialist unit responsible for the prosecution of serious and high profile fraud, terrorist and special interest criminal matters including the Stansted Airport Afghan hijacking and the prosecution of Paul Burrell (Princess Diana’s butler). Michael joined Peters & Peters in 2002. He became a partner in May 2004, and Head of the Business Crime team in May 2009. Since joining Peters & Peters, Michael has dealt with a wide range of business crime matters. He has particular expertise in international sanctions, criminal cartels, extradition, corruption, mutual legal assistance, and FSA investigations. Described as“ an influential practitioner in fraud and regulatory work, so much so that he is top of the referral lists of many City firms for independent advice for directors” (The Lawyer’s Hot 100 2009), he was recognised as one of the UK’s most innovative lawyers in the 2011 FT Innovative Lawyer Awards and included in the list of the UK's leading lawyers in 'The International Who's Who of Asset Recovery 2012. In 2012 he was the winner of the Global Competition Review Article of the Year. Michael regularly appears on television and radio to discuss his specialist areas and he is the author of the leading textbook on the UK Criminal Cartel Offence “The Law of Criminal Cartels-Practice and Procedure” (Oxford University Press 2009). Recent/Current Sanctions Work • Representing 109 individuals and 12 companies subject to designation by the European Council under targeted measures imposed against Zimbabwe. This is the largest and most complex collective challenge to a sanctions listing ever brought before the European Court. • Acting for a former Egyptian Minister and his UK resident wife, challenging their designation by the European Council of Ministers under targeted measures brought against former members of the Egyptian Government. • Advising a company accused in a UN investigation report to have breached UN sanctions imposed in relation to Somalia. • Advising a UK company in relation to ongoing commercial relationships with an Iranian company listed under both EU and UN sanctions. • Advising an individual in relation to a UK investigation for alleging breaching nuclear export controls.

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