The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes the evolving situation as of Thursday, March 31 concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This post supplements our previous analysis all of which are linked at the end of today’s content.

United States Targets Russian Sanctions Evaders in the Latest Round of Designations

On March 31, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced the designation of still more entities and individuals as it expands sanctions against Russia. These parties have been designated as Specially Designated Nationals (SDN); as a general matter, U.S. persons are prohibited from conducting any transaction with an SDN.

The designations cover several different Russian actors, including network and front companies involved in providing western technology to Russia’s defense sector as follows:

  • Moscow-based OOO Serniya Engineering (Serniya).
  • Moscow-based OOO Sertal (Sertal).
  • Russia-based OOO Robin Treid (front company for Serniya).
  • K.-based Majory LLP (front company for Serniya).
  • K.-based Photon Pro LLP (front company for Serniya).
  • Spain-based Invention Bridge SL (acting for Serniya).
  • Singapore-based Alexsong Pte Ltd (supporting sanctions evasion by Serniya).

Individual Company Officials, Leaders Also Designated

In addition to the entities, OFAC designated individuals acting on behalf of or for being leaders, officials, senior executives, or board members of the sanctioned companies:

  • Irina Viktorovna Nikolaeva (acting on behalf of Serniya).
  • Yevgeniya Aleksandrovna Podgornova (acting on behalf of Serniya).
  • Sergey Aleksandrovich Yershov (acting on behalf of Serniya).
  • Anton Alekseevich Krugovov (acting on behalf of Serniya and senior officer of Majory LLP).
  • Andrey Georgiyevich Zakharov (acting on behalf of Serniya).
  • Yevgeniy Aleksandrovich Grinin (acting on behalf of Serniya and a leader of Photon Pro LLP).
  • Sergey Aleksandrovish Yershov (a leader of Serniya and acting on behalf of Sertal).
  • Viacheslav Yuryevich Dubrovinskiy (a leader of Serniya).
  • Tamara Aleksandrovna Topchi (a leader of Invention Bridge SL).

OFAC also blocked three companies owned or controlled by two of these individuals:

  • Russia-based OOO Nauchno-Tekhnicheskii Tsentr Metrotek (owned/controlled by Andrey Georgiyevich Zakharov).
  • Russia-based OOO Pamkin Khaus (owned/controlled by Andrey Georgiyevich Zakharov).
  • Russia-based OOO Foton Pro (owned/controlled by Yevgeniy Aleksandrovich Grinin).

Additional Designations Based on Company’s Role in Acquiring Dual-Use Products

OFAC designated Evgeniya Vladimirovna Bernova and certain of her companies operating in Europe, along with a director of one of the companies, for their role in acquiring dual-use equipment on behalf of Russian end-users:

  • Malta-based Malberg Ltd (Bernova’s company).
  • Nikita Alexsandrovich Sobolev (director of Malberg).
  • K.-based Djeco Group LP (Bernova’s shell company).
  • Malta-based Djeco Group Holding Ltd (Bernova’s shell company).
  • Malta-based Maltarent Ltd. (Bernova’s shell company).
  • France-based SCI Griber (Bernova’s shell company).
  • Moscow-based Sernia-Film Co. Ltd (Bernova served as director).

Russian High Technology Companies Designated for Enabling War

OFAC designated the following communications and electronics companies for operating in the Russian technology sector and supporting Russia’s war effort:

  • AO NII-Vektor, software and communications technology company (for providing the capability to track ships, aircraft, and ground vehicles during Russia’s invasion of Ukraine).
  • Joint Stock Company Mikron, Russia’s largest manufacturer/exporter of microelectronics (for producing chips for Mir, Russia’s National Payment Card System).
  • Molecular Electronics Research Institute, R&D institute (for research and design work for the Government of Russia).

Treasury Expands Russia Sanctions Authority

Also today, Treasury Secretary Yellen issued a Determination pursuant to Executive Order (EO) 14024 that extends sanctions to cover companies operating in the Russian aerospace, marine, and/or electronics sectors. Though no sanctions on parties in these sectors have yet been announced, the determination paves the way for such sanctions. This builds on the previous determination related to the financial services sector of Russia’s economy and the original authority under EO 14024, which established authority to impose sanctions on parties in the technology and defense sectors of Russia’s economy.

OFAC Continues to Designate Russian, Other Actors Even Not Directly Related to Ukraine

Though not directly related to Russia’s invasion of Ukraine, OFAC also announced that it is designating employees of the State Research Center of the Russian Federation Central Scientific Research Institute of Chemistry and Mechanics (TsNIIKhM) for their role in the August 2017 cyber attack on a Middle East petrochemical facility. Those individuals are:

  • Evgeny Viktorovich Gladkikh, an employee of TsNIIKhM Applied Development Center.
  • Servei Alekseevich Bobkov, General Director of TsNIIKhM.
  • Konstantin Vasilyevich Malevanyy, Deputy General Director of TsNIIKhM.

Also today, OFAC designated Quantlog OY, a Finnish front company established by Nikita Gennadievitch Kovalevskij, an individual designated in September 2020 for involvement in procuring underwater dive equipment for the Russian Federal Security Service (FSB).

If you have any questions or need assistance related to this evolving situation or other international trade matters, please contact the authors. To read our previous coverage concerning the Russia-Ukraine situation, click the links below:

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Photo of Mi-Yong Kim Mi-Yong Kim

Mi-Yong Kim has nearly 25 years of experience related to export controls and national security. Based on her extensive government service, she is uniquely well equipped to provide advice to help clients navigate the complex regulations related to export controls and national security…

Mi-Yong Kim has nearly 25 years of experience related to export controls and national security. Based on her extensive government service, she is uniquely well equipped to provide advice to help clients navigate the complex regulations related to export controls and national security, including matters related to compliance with the Export Administration Regulations (EAR); the International Traffic in Arms Regulations (ITAR); the Committee on Foreign Investment in the United States (CFIUS); and foreign ownership, control, or influence (FOCI) mitigation by the Defense Security Service. Mi-Yong is also an Adjunct Professor at the National Chengchi University (NCCU) in Taipei, Taiwan. She teaches a graduate-level class on export controls and related topics at the College of International Affairs of NCCU.

Photo of Thad McBride Thad McBride

Thad McBride advises public and private companies on the legal considerations essential to successful business operations in a global marketplace. He focuses his practice on counseling clients on compliance with U.S. export regulations (ITAR and EAR), economic sanctions and embargoes, import controls (CBP)…

Thad McBride advises public and private companies on the legal considerations essential to successful business operations in a global marketplace. He focuses his practice on counseling clients on compliance with U.S. export regulations (ITAR and EAR), economic sanctions and embargoes, import controls (CBP), and the Foreign Corrupt Practices Act (FCPA). He also advises clients on anti-boycott controls, and assists companies with matters involving the Committee on Foreign Investment in the United States (CFIUS). Thad supports international companies across a range of industries, including aviation, automotive, defense, energy, financial services, manufacturing, medical devices, oilfield services, professional services, research and development, retail, and technology. Beyond advising on day-to-day compliance matters, Thad regularly assists clients in investigations and enforcement actions brought by government agencies, including the U.S. Department of Justice (DOJ), the U.S. Treasury Department Office of Foreign Assets Control (OFAC), the U.S. State Department Directorate of Defense Trade Controls (DDTC), Customs and Border Protection (CBP), the U.S. Commerce Department Bureau of Industry & Security (BIS), and the Securities & Exchange Commission.

Photo of Sylvia Yi Sylvia Yi

Sylvia Yi represents businesses across a broad range of sectors as they move through the contracting process with federal, state and local governments, and when they engage in international transactions. Sylvia counsels public and private companies on day to day compliance challenges, and…

Sylvia Yi represents businesses across a broad range of sectors as they move through the contracting process with federal, state and local governments, and when they engage in international transactions. Sylvia counsels public and private companies on day to day compliance challenges, and supports clients in responding to criminal and government investigations. She is a regular contributor to the firm’s Government Contracts & International Trade Blog, where she provides insight on the demanding and ever-changing regulatory environment.