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All together now: OFAC makes updates in Cyber, Yemen, Ukraine/Russia & non-proliferation programs

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Today, OFAC added the following persons:

AL-HAMZI, Ahmad (Arabic: أحمد الحمزي) (a.k.a. AL-HAMZI, Ahmad ‘Ali; a.k.a. AL-HAMZI, Ahmad ‘Ali Ahsan; a.k.a. AL-HAMZI, Ahmed Ali; a.k.a. “AL-HAMZI, Muti'”), Yemen; DOB 1985; POB Sanaa al-Hamzat, Yemen; nationality Yemen; Gender Male; Commander of the Houthi Air Force (individual) [YEMEN]. 
 
AL-SA’ADI, Mansur (a.k.a. AL SAADI, Mansoor Ahmed; a.k.a. AL-SA’ADI, Mansur Ahmad; a.k.a. “Abu Sajjad”), Yemen; DOB 1988; nationality Yemen; Gender Male; Houthi Commander of Yemen’s Naval and Coastal Defense Forces (individual) [YEMEN]. 

to its Yemen-related sanctions program, and the following persons:

BORTNIKOV, Aleksandr Vasilievich (Cyrillic: БОРТНИКОВ, Александр Васильевич), Moscow, Russia; DOB 15 Nov 1951; POB Perm, Russia; nationality Russia; Gender Male (individual) [NPWMD] [UKRAINE-EO13661] (Linked To: FEDERAL SECURITY SERVICE). 
 
KALASHNIKOV, Alexander Petrovich (Cyrillic: КАЛАШНИКОВ, Александр Петрович) (a.k.a. KALASHNIKOV, Aleksandr (Cyrillic: КАЛАШНИКОВ, Александр)), Russia; DOB 27 Jan 1964; POB Tatarsk, Novosibirsk Region, Russia; nationality Russia; Gender Male (individual) [UKRAINE-EO13661]. 
 
KIRIYENKO, Sergei Vladilenovich (Cyrillic: КИРИЕНКО, Сергей Владиленович), Moscow, Russia; DOB 26 Jul 1962; POB Sukhumi, Georgia; nationality Russia; Gender Male (individual) [UKRAINE-EO13661]. 
 
KRASNOV, Igor Victorovich (Cyrillic: КРАСНОВ, Игорь Викторович) (a.k.a. KRASNOV, Igor (Cyrillic: КРАСНОВ, Игорь); a.k.a. KRASNOV, Igor Viktorovich), 6-3 Michurinsky Prospekt, Moscow, Russia; DOB 24 Dec 1975; POB Arkhangelsk, Russia; nationality Russia; Gender Male (individual) [UKRAINE-EO13661]. 
 
KRIVORUCHKO, Aleksei Yurievich (Cyrillic: КРИВОРУЧКО, Алексей Юрьевич), Russia; DOB 17 Jul 1975; POB Stavropol, Russia; nationality Russia; Gender Male (individual) [UKRAINE-EO13661]. 
 
POPOV, Pavel Anatolievich (Cyrillic: ПОПОВ, Павел Анатольевич), Russia; DOB 01 Jan 1957; POB Krasnoyarsk, Russia; nationality Russia; Gender Male (individual) [UKRAINE-EO13661]. 
 
YARIN, Andrei Veniaminovich (Cyrillic: ЯРИН, Aндрей Вениаминович), Moscow, Russia; DOB 13 Feb 1970; POB Nizhny Tagil, Russia; nationality Russia; Gender Male (individual) [UKRAINE-EO13661]. 

to its Ukraine/Russia-related sanctions program under Executive Order 13661 (Bortnikov is also sanctioned under the Non-Proliferation of Weapons of Mass Destruction – NPWMD – program), and the following entities:

27TH SCIENTIFIC CENTER (a.k.a. “27TH NTS”), Brigadirskiy Pereulok 13, Moscow 105005, Russia [NPWMD]. 
 
33RD SCIENTIFIC RESEARCH AND TESTING INSTITUTE (a.k.a. “33RD TSNIII”), 1 Ulitsa Krasnoznamennaya, Volsk-18/ Shikhany, Saratov Oblast, Russia [NPWMD]. 
 
STATE SCIENTIFIC RESEARCH INSTITUTE OF ORGANIC CHEMISTRY AND TECHNOLOGY (a.k.a. GOSNIIOKHT), Shosse Entuziastov 23, Moscow, Moscow Oblast, Russia [NPWMD].

under the NPWMD non-proliferation program.

Additionally, the following existing listings:

CHEPIGA, Anatoliy Vladimirovich (a.k.a. BOSHIROV, Ruslan), Moscow, Russia; DOB 05 Apr 1979; alt. DOB 12 Apr 1978; POB Nikolaevka, Amur Oblast, Russia; alt. POB Dushanbe, Tajikistan; nationality Russia; Gender Male (individual) [CAATSA – RUSSIA] (Linked To: MAIN INTELLIGENCE DIRECTORATE). -to- CHEPIGA, Anatoliy Vladimirovich (a.k.a. BOSHIROV, Ruslan), Moscow, Russia; DOB 05 Apr 1979; alt. DOB 12 Apr 1978; POB Nikolaevka, Amur Oblast, Russia; alt. POB Dushanbe, Tajikistan; nationality Russia; Gender Male (individual) [NPWMD] [CAATSA – RUSSIA] (Linked To: MAIN INTELLIGENCE DIRECTORATE). 
 
FEDERAL SECURITY SERVICE (a.k.a. FEDERALNAYA SLUZHBA BEZOPASNOSTI; a.k.a. FSB), Ulitsa Kuznetskiy Most, Dom 22, Moscow 107031, Russia; Lubyanskaya Ploschad, Dom 2, Moscow 107031, Russia [CYBER2] [CAATSA – RUSSIA]. -to- FEDERAL SECURITY SERVICE (a.k.a. FEDERALNAYA SLUZHBA BEZOPASNOSTI; a.k.a. FSB), Ulitsa Kuznetskiy Most, Dom 22, Moscow 107031, Russia; Lubyanskaya Ploschad, Dom 2, Moscow 107031, Russia [NPWMD] [CYBER2] [CAATSA – RUSSIA]. 
 
MAIN INTELLIGENCE DIRECTORATE (a.k.a. GLAVNOE RAZVEDYVATEL’NOE UPRAVLENIE (Cyrillic: ГЛАВНОЕ РАЗВЕДЫВАТЕЛЬНОЕ УПРАВЛЕНИЕ); a.k.a. GRU; a.k.a. MAIN DIRECTORATE OF THE GENERAL STAFF; a.k.a. MAIN INTELLIGENCE DEPARTMENT), Khoroshevskoye Shosse 76, Khodinka, Moscow, Russia; Ministry of Defence of the Russian Federation, Frunzenskaya nab., 22/2, Moscow 119160, Russia [CYBER2] [CAATSA – RUSSIA]. -to- MAIN INTELLIGENCE DIRECTORATE (a.k.a. GLAVNOE RAZVEDYVATEL’NOE UPRAVLENIE (Cyrillic: ГЛАВНОЕ РАЗВЕДЫВАТЕЛЬНОЕ УПРАВЛЕНИЕ); a.k.a. GRU; a.k.a. MAIN DIRECTORATE OF THE GENERAL STAFF; a.k.a. MAIN INTELLIGENCE DEPARTMENT), Khoroshevskoye Shosse 76, Khodinka, Moscow, Russia; Ministry of Defence of the Russian Federation, Frunzenskaya nab., 22/2, Moscow 119160, Russia [NPWMD] [CYBER2] [CAATSA – RUSSIA]. 
 
MISHKIN, Alexander Yevgeniyevich (a.k.a. PETROV, Alexander), Moscow, Russia; DOB 13 Jul 1979; POB Loyga, Russia; alt. POB Kotlas, Russia; nationality Russia; Gender Male (individual) [CAATSA – RUSSIA] (Linked To: MAIN INTELLIGENCE DIRECTORATE). -to- MISHKIN, Alexander Yevgeniyevich (a.k.a. PETROV, Alexander), Moscow, Russia; DOB 13 Jul 1979; POB Loyga, Russia; alt. POB Kotlas, Russia; nationality Russia; Gender Male (individual) [NPWMD] [CAATSA – RUSSIA] (Linked To: MAIN INTELLIGENCE DIRECTORATE). 

were updating by adding them to the NPWMD program.

Cyber-Related General License 1 (related to the FSB) was updated to version B – at first glance, it looks like it was just amended to include references to the WMD program (since the FSB is now designated under that program).

Finally, OFAC amended existing Frequently Asked Questions (FAQs) 501, 502 and 503.

And Treasury:

PRESS RELEASES

Treasury Sanctions Russian Officials in Response to the Novichok Poisoning of Aleksey Navalny

WASHINGTON – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) joined the U.S. Departments of State and Commerce in imposing sanctions in response to Russia’s poisoning and subsequent imprisonment of Russian opposition figure Aleksey Navalny.  Specifically, OFAC designated seven Russian government officials:  Federal Security Service (FSB) Director Aleksandr Bortnikov (Bortnikov), Chief of the Presidential Policy Directorate Andrei Yarin (Yarin), First Deputy Chief of Staff of the Presidential Executive Office Sergei Kiriyenko (Kiriyenko), Deputy Minister of Defense Aleksey Krivoruchko (Krivoruchko), Deputy Minister of Defense Pavel Popov (Popov), Federal Penitentiary Service (FSIN) director Alexander Kalashnikov (Kalashnikov), and Prosecutor General Igor Krasnov (Krasnov) pursuant to Executive Order (E.O.) 13661 for serving as officials of the Russian government.  OFAC also designated Bortnikov pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, the Federal Security Service (FSB).  

“The Kremlin’s use of chemical weapons to silence a political opponent and intimidate others demonstrates its flagrant disregard for international norms,” stated Secretary Janet L. Yellen. “We join the EU in condemning Alexei Navalny’s poisoning as well as his arrest and imprisonment by the Russian government.”

FSB OFFICERS POISONED NAVALNY WITH A NOVICHOK NERVE AGENT 

On August 24, 2020, German doctors announced that Navalny had been poisoned with a substance that analysis by German, French, Swedish, and Organisation for the Prohibition of Chemical Weapons (OPCW)-designated laboratories later identified as a Novichok nerve agent.  Novichok nerve agents were created by the former Soviet Union, and Russia is the only known country to have used these chemical weapons.  Russia previously used a Novichok nerve agent in the March 2018 attempted assassination of former Russian military intelligence officer Sergei Skripal in Salisbury, United Kingdom.  In response, OFAC sanctioned several Russian persons associated with the Skripal attack, under multiple authorities, and also implemented prohibitions pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991.

The United States believes that the FSB used a nerve agent to poison Navalny, who fell gravely ill on August 20, 2020 while traveling after campaigning against pro-Kremlin candidates in regional elections held in September 2020.  Navalny has for many years been the target of FSB surveillance, including wiretapping and covert video surveillance.

The European Union (EU) and United Kingdom (UK) have similarly stated that Navalny has been the target of systematic harassment and repression by state and judicial actors due to his prominent role in the political opposition, and was under surveillance at the time of his poisoning.  Given that the toxic agent with which Navalny was poisoned is only accessible to Russian state authorities, the EU and UK concluded that the poisoning was only possible with the involvement of the FSB.

TREASURY ACTIONS

Today’s Treasury action complements today’s EU actions as well as those taken in October 2020 by the EU and the United Kingdom, which imposed sanctions on senior Russian government officials and a Russian state research institute for their involvement in the poisoning of Navalny. 

Andrei Yarin is the chief of the Kremlin’s domestic policy directorate.  In this function, he is in charge of designing and implementing internal political orientations.  Yarin was appointed to a task force inside the Presidential Executive Office whose role was to counter Navalny’s influence in Russian society, including through operations meant to discredit him.

Sergei Kiriyenko is the First Deputy Chief of Staff of the Presidential Executive Office.  Kiriyenko is reported to be President Putin’s “domestic policy curator.”

Aleksei Krivoruchko is a Deputy Minister of Defense of the Russian Federation.  Krivoruchko was previously the chief executive officer of U.S.-designated Kalashnikov Concern.  In his role as Deputy Defense Minister, Krivoruchko has overall responsibility for armaments, including oversight of the Ministry’s stocks of weapons and military equipment.

Pavel Popov is a Deputy Minister of Defense of the Russian Federation.  In his capacity as Defense Minister, Popov is responsible for research activities that include oversight and development of the Defense Ministry’s scientific and technical capabilities.

Alexander Bortnikov is the Director of the FSB.  As Russia’s internal intelligence service, the FSB is involved in the political prosecutions of opponents of President Vladimir Putin’s regime, and operates as a key political enforcer.  OFAC has previously sanctioned the FSB pursuant to E.O. 13694, as amended by E.O. 13757, as well as Section 224 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), for malicious cyber activities.

Alexander Kalashnikov is the director of the FSIN.  The FSIN accused Navalny of violating the terms of his parole while he was recovering in Germany following his poisoning, sought his arrest, and requested that Navalny’s suspended sentence be converted into an actual prison term.

Igor Krasnov is Russia’s Prosecutor General.  The Prosecutor General’s office has prosecuted Navalny and has pushed for his incarceration.

All seven of these officials were designated pursuant to E.O. 13661 for serving as officials of the Russian government.  In addition, Bortnikov was designated pursuant to E.O. 13382 for acting or purporting to act for or on behalf of, directly or indirectly, the FSB.  

President Putin’s envoy to the Siberian Federal District, Sergei Menyailo, was also designated by the EU and the UK in October 2020 for his involvement in the Navlany poisoning.  Menyailo was previously designated by OFAC on June 20, 2014 pursuant to E.O. 13361 for being responsible for or complicit in actions or policies that threaten the peace, security, stability, sovereignty and, or territorial integrity of Ukraine. 

STATE ACTIONS

Today, the Department of State designated the FSB, GosNIIOKhT, the 33rd TsNIII, the 27th Scientific Center, the GRU, and GRU officers Alexander Yevgeniyevich Mishkin and Anatoliy Vladimirovich Chepiga pursuant to Section 1(a)(ii) of E.O. 13382 for having engaged, or attempted to engage, in activities or transactions that have materially contributed to, or pose a risk of materially contributing to, the proliferation of weapons of mass destruction or their means of delivery (including missiles capable of delivering such weapons), including any efforts to manufacture, acquire, possess, develop, transport, transfer or use such items, by Russia.  GosNIIOKhT was previously sanctioned by the EU and the UK in October 2020.  The Department of State also added six entities to the Countering America’s Adversaries Through Sanctions Act Section 231 List of Specified Persons, as persons that are part of, or operate for or on behalf of, the defense or intelligence sectors of the Government of the Russian Federation.  Finally, the Department of State implemented financial prohibitions pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991.

View the Department of State’s fact sheet and statement on today’s actions.

SANCTIONS IMPLICATIONS

As a result of Treasury’s actions, all property and interests in property of these persons that come within the possession of U.S. persons are blocked, and U.S. persons are generally

prohibited from engaging in transactions with them.  Additionally, any entities 50 percent or

more owned by one or more designated persons are also blocked.  Moreover, any foreign person who knowingly facilitates a significant transaction or transactions for or on behalf of one of these persons risks being sanctioned.

issued press releases about the Ukraine and WMD-related changes (I published the Yemen-related ones earlier).

State has also issued a press release and a Fact Sheet, too, but the links are currently not working – I will post when they are fixed.

Links:

OFAC Notice

Cyber-Related General License 1B

FAQ 501, 502, 503

Treasury Press Release


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