OFAC sanctions individuals and entities connected to Russia’s corruption in Moldova

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On June 5, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 14024, against seven leading members of a Russian intelligence-linked group and an entity connected to one of these individuals, for their role in “the destabilization campaign and continued malign influence campaigns in Moldova.” OFAC previously sanctioned individuals and entities endeavoring in similar efforts to undermine Moldova’s democracy, (covered by InfoBytes here). OFAC also mentioned in the announcement that the EU sanctioned Russian and Moldovan individuals for the same crimes. The designated individuals for these sanctions, OFAC said, are part of a global information operation connected to the Russian Federation—targeting not only Moldova, but other Balkan countries, the EU, UK, and U.S.—that provokes anti-government demonstrations designed to instill fear that undermines faith in democratic principles. Notably, the actors designated were part of a plot to “capitalize on these protests in Chisinau and seize the Moldovan Government House,” OFAC stated. As a result of these sanctions, all property and interests in property belonging to the sanctioned persons that are in the U.S. or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Further, “any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked.” U.S. persons are prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons, unless exempt or authorized by a general or specific OFAC license. Additionally, OFAC warned that financial institutions and other persons that engage in certain transactions or activities with the sanctioned persons may themselves be exposed to sanctions or be subject to an enforcement action.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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