US, Canada, EU Impose New Sanctions on Russia

This Round Includes US Export Control Sanctions on Trade in Controlled Products and Technology

As anticipated by rumblings over the weekend, early Monday morning, April 28, 2014, the United States (US), Canadian, and European Union (EU) governments announced additional economic and export sanctions on Russia. Russia has not officially replied but past behavior indicates that they will likely respond in kind. In the meantime, companies should continue to evaluate their international business partners and investments, and update their screening efforts to reflect these new developments.

United States

The US sanctions are as follows:

The US Department of Treasury Office of Foreign Assets Control (OFAC) has added seven Russian government officials, as well as 17 companies with links to Vladimir Putin’s close associates, to the Specially Designated Nationals List. Those designated are listed below.
US Department of Commerce’s Bureau of Industry and Security (BIS) has announced that it:
- Has added the following entities to the entity list — Stroytransgaz Holding, located in Cyprus; Volga Group, located in Luxembourg and Russia; and Aquanika, Avia Group LLC, Avia Group Nord LLC, CJSC Zest, Sakhatrans LLC, Stroygazmontazh, Stroytransgaz Group, Stroytransgaz LLC, Stroytransgaz-M LLC, Stroytransgaz OJSC, and Transoil, all located in Russia;
- Will deny pending applications for licenses to export or re-export any high technology item subject to the EAR to Russia or occupied Crimea that contribute to Russia’s military capabilities;
- Will take actions to revoke any existing export licenses which meet these conditions; and
- Will review all other pending applications and existing licenses on a case-by-case basis to determine their contribution to Russia’s military capabilities.

BIS has indicated that the United States “will continue to adjust its export licensing policies toward Russia as warranted by Russia’s actions in Ukraine. We urge Russia to honor the commitments it made in Geneva on April 17 to deescalate the situation in Ukraine.”

We understand that BIS will be issuing additional guidance on these export control sanctions in the coming days. However, BIS will conduct a review of existing licenses to see if they contribute to Russian’s military capabilities. If they conclude this test is met, BIS plans to notify license-holders. Until that time, however, the existing licenses continue to be valid.

Canada

Canada likewise continued to add parties to its list, adding nine individuals, allies of Russian President Putin, and two banks to the list. Canada’s additions are below.

European Union

The EU also imposed sanctions on 15 Russian and Ukranian individuals but no entities on April 29.

New US SDN Designations:

The following individuals have been added to OFAC’s SDN List:

BELAVENCEV, Oleg Evgenyevich (a.k.a. BELAVENTSEV, Oleg); DOB 15 Sep 1949; Russian Presidential Envoy to the Crimean District; Member of the Russian Security Council (individual) [UKRAINE2].
CHEMEZOV, Sergei (a.k.a. CHEMEZOV, Sergey Viktorovich); DOB 20 Aug 1952; POB Cheremkhovo, Irkutsk, Russia (individual) [UKRAINE2].
KOZAK, Dmitry; DOB 07 Nov 1958; POB Kirovograd, Ukraine; Deputy Prime Minister of the Russian Federation (individual) [UKRAINE2].
MUROV, Evgeniy Alekseyevich (a.k.a. MUROV, Evgeny; a.k.a. MUROV, Yevgeniy; a.k.a. MUROV, Yevgeny); DOB 18 Nov 1945; POB Zvenigorod, Moscow, Russia; Director of the Federal Protective Service of the Russian Federation; Army General (individual) [UKRAINE2].
PUSHKOV, Aleksei Konstantinovich (a.k.a. PUSHKOV, Alexei); DOB 10 Aug 1954; Chairman of State Duma Committee on International Affairs (individual) [UKRAINE2].
SECHIN, Igor; DOB 07 Sep 1960; POB St. Petersburg, Russia (individual) [UKRAINE2].
VOLODIN, Vyacheslav; DOB 04 Feb 1964; POB Alexeyevka, Khvalynsk district, Saratov, Russia; First Deputy Chief of Staff of the Presidential Executive Office (individual) [UKRAINE2].

The following entities have been added to OFAC’s SDN List:

AQUANIKA (a.k.a. AQUANIKA LLC; a.k.a. LLC RUSSKOYE VREMYA; a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU RUSSKOE VREMYA; a.k.a. RUSSKOE VREMYA OOO; a.k.a. RUSSKOYE VREMYA LLC), 47A, Sevastopolskiy Ave., of. 304, Moscow 117186, Russia; 1/2 Rodnikovaya ul., Savasleika s., Kulebakski raion, Nizhegorodskaya oblast 607007, Russia; Website http://www.aquanika.com; alt. Website http://aquanikacompany.ru; Email Address office@aquanika.com; Registration ID 1075247000036 [UKRAINE2].
AVIA GROUP LLC (a.k.a. AVIA GROUP LTD), Terminal Aeroport Sheremetyevo Khimki, 141400 Moskovskaya obl., Russia; Website http://www.avia-group.su/ [UKRAINE2].
AVIA GROUP NORD LLC, 17 A, Stratoyava St., Saint Petersburg, Russia; Website http://www.ag-nord.ru [UKRAINE2].
CJSC ZEST (a.k.a. ZEST LEASING), pr. Medikov 5, of. 301, St. Petersburg, Russia; 2 Liter a Pl. Rastrelli, St. Petersburg 191124, Russia; Website http://www.zest-leasing.ru; Registration ID 1027809190507; Government Gazette Number 44323193 [UKRAINE2].
INVESTCAPITALBANK (a.k.a. INVESTKAPITALBANK; a.k.a. OJSC INVESTCAPITALBANK; a.k.a. OPEN JOINT STOCK COMPANY INVESTCAPITALBANK), 100/1, Dostoevskogo Street, Ufa, Bashkortostan Republic 450077, Russia; SWIFT/BIC INAKRU41; Website http://www.investcapitalbank.ru; License 2377 [UKRAINE2].
JSB SOBINBANK (a.k.a. SOBINBANK), 15 Korp. 56 D. 4 Etazh ul. Rochdelskaya, Moscow 123022, Russia; 15/56 Rochdelskaya Street, Moscow 123022, Russia; SWIFT/BIC SBBARUMM; Website http://www.sobinbank.ru; Registration ID 1027739051009; Government Gazette Number 09610355 [UKRAINE2].
SAKHATRANS LLC (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU SAKHA (YAKUTSKAYA) TRANSPORTNAYA KOMPANIYA; a.k.a. SAKHATRANS OOO), 14 ul. Molodezhnaya Rabochi Pos. Vanino, 682860 Vaninski, Raion Khabarovski Krai, Russia [UKRAINE2].
SMP BANK (a.k.a. BANK SEVERNY MORSKOY PUT; a.k.a. SMP BANK OPEN JOINT-STOCK COMPANY), 71/11 Sadovnicheskaya Street, Moscow 115035, Russia; SWIFT/BIC SMBKRUMM; Website www.smpbank.ru; Email Address smpbank@smpbank.ru [UKRAINE2].
STROYGAZMONTAZH (a.k.a. LIMITED LIABILITY COMPANY STROYGAZMONTAZH; a.k.a. STROYGAZMONTAZH CORPORATION; a.k.a. “SGM”), 53 prospekt Vernadskogo, Moscow 119415, Russia; Website www.ooosgm.com; alt. Website www.ooosgm.ru; Email Address info@ooosgm.ru [UKRAINE2].
STROYTRANSGAZ GROUP (a.k.a. STROYTRANSGAZ; a.k.a. “STG GROUP”), 3 Begovaya Street, Building #1, Moscow 125284, Russia; Website www.stroytransgaz.ru [UKRAINE2].
STROYTRANSGAZ HOLDING (a.k.a. STG HOLDING LIMITED; a.k.a. STG HOLDINGS LIMITED; a.k.a. STROYTRANSGAZ HOLDING LIMITED; a.k.a. “STGH”), 33 Stasinou Street, Office 2 2003, Nicosia Strovolos, Cyprus [UKRAINE2].
STROYTRANSGAZ LLC (a.k.a. OOO STROYTRANSGAZ), House 65, Novocheremushkinskaya, Moscow 117418, Russia [UKRAINE2].
STROYTRANSGAZ OJSC (a.k.a. OAO STROYTRANSGAZ), House 58, Novocheremushkinskaya St., Moscow 117418, Russia [UKRAINE2].
STROYTRANSGAZ-M LLC, 26th Meeting of the Communist Party Street, House 2V, Novy Urengoy, Tyumenskaya Oblast, Yamalo-Nenetsky Autonomous Region 629305, Russia [UKRAINE2].
THE LIMITED LIABILITY COMPANY INVESTMENT COMPANY ABROS (a.k.a. LLC IC ABROS), 2 Liter a Pl. Rastrelli, St. Petersburg 191124, Russia; Government Gazette Number 72426791; Telephone: 7812 3358979 [UKRAINE2].
TRANSOIL (a.k.a. LIMITED LIABILITY COMPANY TRANSOIL; f.k.a. OBSHCHESTVO S ORGANICHERNNOI OTVETSTVENNOSTYU TRANSOIL; a.k.a. TRANSOIL LLC; a.k.a. TRANSOYL SNG LTD.), 18A Petrogradskaya nab., St. Petersburg 197046, Russia; Website http://www.transoil-spb.ru; alt. Website http://transoil.com; Email Address info@toil.spb.ru; Registration ID 1037835069986 [UKRAINE2].
VOLGA GROUP (a.k.a. VOLGA GROUP INVESTMENTS; f.k.a. VOLGA RESOURCES; f.k.a. VOLGA RESOURCES GROUP), 3, rue de la Reine L-2418, Luxembourg; Russia [UKRAINE2].

New Canadian Designations:

Paragraph 2(a) of the Special Economic Measures (Russia) Regulations1 is replaced by the following:
1. a person engaged in activities that directly or indirectly facilitate, support, provide funding for or contribute to a violation or attempted violation of the sovereignty or territorial integrity of Ukraine;
Part 1 of the schedule to the Regulations is amended by adding the following after item 32:
1. Vyaecheslav VOLODIN
2. Dmitry KOZAK
3. Aleksey PUSHKOV
4. Alexander Mikhailovich BABAKOV
5. Oleg Evgenyevich BELAVENTSEV
6. Evgeniy Alexsevevich MOROV
7. Vladimir Volfovich ZHIRINOVSKY
8. Arkady ROTENBERG
9. Boris ROTENBERG
Part 2 of the schedule to the Regulations is amended by adding the following after item 1:
1. ExpoBank
2. RosEnergoBank

New EU Designations:

Name	Identifying Information	Reasons
Dmitry Nikolayevich KOZAK	Born 7.11.1958 in Kirovohrad, Ukrainian SSR	Deputy Prime Minister. Responsible for overseeing the integration of the annexed Autonomous Republic of Crimea into the Russian Federation.
Oleg Yevgenyvich BELAVENTSEV	Born 15.9.1949 in Moscow	Plenipotentiary Representative of the President of the Russian Federation into the so called ‘Crimean Federal District’, Non-permanent member of the Russian Security Council. Responsible for the implementation of the constitutional prerogatives of the Russian Head of State on the territory of the annexed Autonomous Republic of Crimea.
Oleg Genrikhovich SAVELYEV	Born 27.10.1965 in Leningrad	Minister for Crimean Affairs. Responsible for the integration of the annexed Autonomous Republic of Crimea into the Russian Federation.
Sergei Ivanovich MENYAILO	Born 22.8.1960 in Alagir, North-Ossetian Autonomous SSR, RSFSR	Acting governor of the Ukrainian annexed city of Sevastopol.
Olga Fedorovna KOVATIDI	Born 7.5.1962 in Simferopol, Ukrainian SSR	Member of the Russian Federation Council from the annexed Autonomous Republic of Crimea.
Ludmila Ivanovna SHVETSOVA	Born 24.9.1949 in Alma-Ata, USSR	Deputy Chairman of State Duma, United Russia — Responsible for initiating legislation to integrate the annexed Autonomous Republic of Crimea into the Russian Federation.
Sergei Ivanovich NEVEROV	Born 21.12.1961 in Tashtagol, USSR	Deputy Chairman of State Duma, United Russia. Responsible for initiating legislation to integrate the annexed Autonomous Republic of Crimea into the Russian Federation.
Igor Dmitrievich SERGUN	Born 28.3.1957	Director of GRU (Main Intelligence Directorate), Deputy Chief of the General Staff of the Armed Forces of the Russian Federation, Lieutenant-General. Responsible for the activity of GRU officers in Eastern Ukraine.
Valery Vasilevich GERASIMOV	Born 8.9.1955 in Kazan	Chief of the General Staff of the Armed Forces of the Russian Federation, First Deputy Minister of Defence of the Russian Federation, General of the Army. Responsible for the massive deployment of Russian troops along the border with Ukraine and lack of de-escalation of the situation.
German PROKOPIV		Active leader of the ‘Lugansk Guard’. Took part in the seizure of the building of the Lugansk regional office of the Security Service, recorded a video address to President Putin and Russia from the occupied building. Close links with the ‘Army of the South-East’.
Valeriy BOLOTOV		One of the leaders of the separatist group ‘Army of the South-East’ which occupied the building of the Security Service in the Lugansk region. Retired officer. Before seizing the building he and other accomplices possessed arms apparently supplied illegally from Russia and from local criminal groups.
Andriy PURGIN		Head of the ‘Donetsk Republic’, active participant and organiser of separatist actions, co-ordinator of actions of the ‘Russian tourists’ in Donetsk. Co-founder of a ‘Civic Initiative of Donbass for the Eurasian Union’.
Denys PUSHYLIN	Born in Makiivka	One of the leaders of the Donetsk People’s Republic. Participated in the seizure and occupation of the regional administration. Active spokesperson for the separatists.
Tsyplakov Sergey GENNADEVICH		One of the leaders of ideologically radical organization People’s Militia of Donbas. He took active part in the seizure of a number of state buildings in Donetsk region.
Igor STRELKOV (Ihor Strielkov)		Identified as staff of Main Intelligence Directorate of the General Staff of the Armed Forces of the Russian Federation (GRU). He was involved in incidents in Sloviansk. He is an assistant on security issues to Sergey Aksionov, self-proclaimed prime-minister of Crimea.

Arent Fox has significant experience in helping companies navigate and comply with US sanctions laws and export controls. If you have any questions regarding the above, please contact Kay C. Georgi, Keith F. Huffman, and Tina Termei with firm’s International Trade group, or the Arent Fox professional who regularly handles your matters.