US Treasury new Sanctions targeting Russia’s technology sector.
US Treasury new Sanctions targeting Russia’s technology sector.
Treasury Targets Sanctions Evasion Networks and Russian Technology Companies Enabling Putin’s War. Also Oleg Vladimirovich Deripaska bid to remove the 2018 sanctions USCCOA-DC DENIED
US Treasury adds more sanctions and sectors…
In its rationale the Treasury concluded the following finding of facts and it’s important to know this so you have a better context to the content…
“align with recent actions taken by the U.S. Department of Commerce targeting these sectors, which are strategically important to Russia’s economic ambitions, long-term technological development, and defense industrial base.”
In the US Treasury’s March 31, 2022 Press Release which states in part:
…Russian technology sector to prevent it from evading unprecedented multilateral sanctions and procure critical western technology. OFAC is designating 21 entities and 13 individuals as part of its crackdown on the Kremlin’s sanctions evasion networks and technology companies, which are instrumental to the Russian Federation’s war machine
And when a press release contains a money flow graphic then you know it’s sort of a big deal - as further explained by the US Treasury Press Release —which definitively proves how Russia has money flows from Maltese and created a very complex web of entities and individuals in an obvious effort to evade US Sanctions…
RUSSIAN SANCTIONS EVASION NETWORKS
Incidentally it’s rather difficult to find the newly added Russian entities from the “official” Russian Government Corporation Database because it keeps defaulting to error 404 or error 410 ←which typically means the data has been deleted and/or the .html link has been misconfigured
Moscow-based OOO Serniya Engineering (Serniya) is at the center of a procurement network engaged in proliferation activities at the direction of Russian Intelligence Services. This network operates across multiple countries to obfuscate the Russian military and intelligence agency end-users that rely on critical western technology. Serniya and Moscow-based OOO Sertal (Sertal) work to illicitly procure dual-use equipment and technology for Russia’s defense sector.
Russia-based OOO Robin Treid (see D&B profile), United Kingdom-based Majory LLP (see UK Corp Database),United Kingdom-based Photon Pro LLP (see UK Corp Database , and Spain-based Invention Bridge SL are front companies utilized by Serniya to facilitate its procurement of key equipment for the Government of the Russian Federation (GoR). Within the past month, the European Union and Japan have placed export-related restrictions on Serniya, Sertal, and Photon Pro. The UK is also taking coordinated action on the companies within its jurisdiction.
Additional entities and individuals:
As noted by the US Treasury - sanctions on Evgeniya Vladimirovna Bernova (Bernova) -the Treasury determined that Bernova is an associate of the Serniya network. Which currently operates the Malta-based Malberg Ltd (Malberg):
“though a multinational web of shell companies. Malberg has worked to deceptively acquire dual-use equipment on behalf of Russian end-users. Bernova’s network includes Malberg’s Director, Nikita Aleksandrovich Sobolev, UK-based Djeco Group LP, Malta-based Djeco Group Holding Ltd, Malta-based Maltarent Ltd, and France-based SCI Griber. In addition, Moscow-based Sernia-Film Co Ltd, where Bernova has served as a director, has facilitated the export of equipment by Malberg to intended government end-users in Russia.”
USA to Malta -revoke Russians Maltese Citizenship…
The Department of Treasury has issued a Determination Pursuant to Section 1(a)(i) of Executive Order 14024 -currently the Government of Malta is rechecking and then stripping Russians of their Maltese Citizenship, you can read more here which confirms the Government of Malta’s revocation of Evgeniya Vladimirovna Bernova and Nikita Aleksandrovich Sobolev “Maltese citizenship” —this is pretty important given that many of Putin’s Oligarchs have previously obtained citizenship “aka Golden Passports” and this has allowed these Oligarchs to move freely because they present their Maltese or Cypriot passports. This isn’t exactly a surprise given their March 3, 2022 Press Release, —which clearly states that Malta officially scraped the Russian Citizenship scheme. But the fact Malta suspended both of the aforementioned newly sanctioned individuals. I’ll repeat this is rather significant
So when I say it’s a big deal that the Malta Government is actively revoking “dual” citizenship —it really is. Now if the Biden Administration and our Allies would put serious pressure on the Thai Government —because Phuket Thailand is a favorite Vacation spot for many wealthy Russians —that would effectively force Russian Oligarch to Spring/Summer vacation in Russia —I hear Sochi is wonderful this time of year (I’m kidding, sort of)
Treasury Secretary Janet Yellen in a statement —stated in part:
Russia not only continues to violate the sovereignty of Ukraine with its unprovoked aggression but also has escalated its attacks striking civilians and population centers...We will continue to target Putin’s war machine with sanctions from every angle, until this senseless war of choice is over.”
And lastly the March 31, 2022 US Treasury Press Release also states, that the department made the determination that adding the three (aforementioned) and new sectors to the crushing sanctions on Russia entities and individuals in response to Putin’s barbaric war on Ukraine. The US Treasury identified the following new sectors ; aerospace, marine and electronics—pursuant to Executive Order 14024. And by adding these new sectors this will enable the Treasury to further identify additional Russian individuals and Business entities. I personally like to think of the new sanctions as an economic death grip on Putin, his Oligarchs and Russia’s economy. And I’m here for all of it and you should be too.
In the event you’re inclined to read the February 2022 article, you can do so here because that article will provide you with a baseline. Or not.
Oleg sorry to hear about your appeal denial…
Okay not really —to be clear and I can not emphasize this point enough —this week the US Circuit Court of Appeals-DC Circuit (USCCOAs-DC) denied Deripaska’s effort to lift the 2018 sanctions (see the 2018 NYTs article when the Trump Administration attempted to lift sanctions for Oleg Deripaska) —as noted in the USCCOAs-DC March 29, 2022 JUDGEMENT which affirmed the lower Court’s decision. It is possible that DERIPASKA might (operative word) as for the full panel (en banc) to review his appeal de novo but again that’s an educated guess on my part and it remains unclear if that’s the next step DERIPASKA “might” take… but as the USCCOAs-DC noted -the lower Court made an appropriate finding of facts and Deripaska’s central arguments failed because he choose not to argue the validity of the various Executive Orders…
As you’ll note, Deripaska’s primary three arguments that the 2018 imposed sanctions were “unlawful” and the District Court was unpersuaded by his arguments:
the sanctions exceeded OFAC’s statutory authority because they responded to a generalized “undeclared national emergency” concerning Russia’s “worldwide malign activities.”
OFAC acted arbitrarily and capriciously
The USCCOAs-DC roundly rejected this argument. Concluding there was zero evidence that our government “acted for reasons other than those it provided.” In addition the USCCOAs-DC also noted that Deripaska failed to argue the validity of the previous executive orders (under the Obama Administration) neither of the 2014 executive orders required a “showing of how the particular sanction related to the emergency” the Court concluded that the lower court’s ruling was correct largely because aforementioned executive orders “do not required a showing of how the particular sanction related to the emergency” - moreover the USCCOAs-DC held that OFAC had not acted arbitrarily and capriciously by sanctioning him under Executive Order 13662 but not sanctioning the energy companies that he operated.
Deripaska next argued that OFAC acted arbitrarily and capriciously, as the OFAC lacked authority to sanction him for conduct that happened before Executive Order 13661‘s effective date. In response, the court stated that the OFAC cited “substantial evidence” that Deripaska acted on behalf of Russian officials after the executive order was issued. The court also rejected Deripaska’s final argument that OFAC acted arbitrarily and capriciously by sanctioning him under Executive Order 13662 but did not sanction his energy companies…
…there is no evidence that the government acted for reasons other than those it provided, much less that its stated reasons were contrived. See Dep’t of Commerce, 139 S. Ct. at 2575-76. …contrary to Deripaska’s suggestions,…neither executive order requires a showing of how the particular sanction bears on the declared emergency; rather, the orders reflect the President’s judgment that the covered actions contribute to the situation in Ukraine. The two cited executive orders plainly cover the types of actions OFAC attributes to Deripaska….
…the record reflects Deripaska’s continuing and extensive operation in the sector: OFAC found, among other things, that Deripaska “owns 44.95 percent of En+, votes 35 percent of En+ shares, and appoints four of 12 board members to the En+ board of directors,” thereby verifying his substantial operation in the sector
And your daily saltwater therapy —also for the next few weeks my Substack activity might be hit or miss. Which shouldn’t come as a surprise because we normally head down to the beach house to finish up home improvement projects in advance of the high season. Because happy vacation renters means a greater ROI. But man the past two years the cost of pressure treated wood has absolutely skyrocketed…
So that’s my round about way of saying I’m going to unplug for a few consecutive days and will intermittently pop back up. But self care is the best care.
Be Well.
Filey
This really is good news--beside Oleg, there's golden passports and cyber actors.
Always grateful for your posts and links, Filey! Relax & Recharge!
Have a wonderful week-end and thanks for the good news about Oleg. ♥️