On July 16, 2014, the United States ratcheted up its sanctions on Russia in connection with escalating tensions in Eastern Ukraine. Specifically, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) announced the imposition of sanctions measures targeting Russian entities in the energy and financial services sectors. In addition, OFAC added a number of Russian and Ukrainian individuals and entities to its Specially Designated Nationals and Blocked Persons list (“SDN list”) and the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) followed suit by adding the same entities to its Entity List. Finally, the European Union announced the forthcoming imposition of additional sanctions on certain Russian entities, as well as the suspension of certain financing/lending transactions.

United States Sanctions
Sectoral Sanctions. Pursuant to Executive Order 13662 (Mar. 20, 2014), which authorized the imposition of sanctions targeting the defense and related materiel, energy, engineering, financial services, and metals and mining sectors of the Russian economy, OFAC has implemented a new type of sanctions list, the Sectoral Sanctions Identification List (“SSIL”), that prescribes certain “less than blocking” sanctions currently targeting listed entities in the financial services and energy sectors, as well as entities 50 percent or more owned by such listed entities (as noted below, blocking sanctions apply to persons identified on the SDN list). While OFAC has stopped short for now of imposing broader sanctions targeting these sectors, the sanctions measures set forth in the SSIL are expected to dramatically curtail access to U.S. debt and, for listed banks, equity financing. Please note that the SSIL is distinct from the SDN list and that identification on the SSIL does not trigger any requirement to block the assets of the listed entities (unless such entities otherwise are designated as SDNs). Rather, U.S. persons are obligated to reject transactions or dealings prohibited by Directive 1 (Financial Services) and Directive 2 (Energy) and, to the extent required, report the rejected transactions to OFAC.

As stated in the SSIL, under Directive 1 U.S. persons, wherever located, are prohibited from involvement in the following: “transacting in, providing financing for, or otherwise dealing in new debt of longer than 90 days maturity or new equity of [the entities set forth in Appendix 1, their property, or their interests in property.” Under Directive 2, as stated in the SSIL, U.S. persons, wherever located, are prohibited from involvement in the following: “transacting in, providing financing for, or otherwise dealing in new debt of longer than 90 days maturity of [the entities set forth in Appendix 2, their property, or their interests in property.” According to OFAC, the “term debt includes bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper. The term equity includes stocks, share issuances, depositary receipts, or any other evidence of title or ownership.” Although the Presidential Directives underlying OFAC’s implementation of the new sanctions use the term debt/equity “for” rather than “of” “the listed entities” it is not clear whether this distinction could have a material impact on the scope of the sanctions, particularly given OFAC’s clarifications, as discussed below.

On their face, these prohibitions appear potentially to be quite broad, but a series of Frequently Asked Questions published by OFAC appear to clarify the scope in a more narrow fashion. In the case of Directive 1, the prohibition extends only to “transacting in, providing financing for, or otherwise dealing in debt with a maturity of longer than 90 days or equity if that debt or equity is issued after on or after July 16, 2014... by, on behalf of, or for the benefit of the persons operating in Russia’s financial sector named under Directive 1, their property, or their interests in property.” 

OFAC further added that the Directive 1 prohibitions apply to “all transactions involving new debt with a maturity of longer than 90 days or new equity; all financing in support of such new debt or new equity; and any dealing in, including provision of services in support of, such new debt or new equity.” In the case of Directive 2, the prohibition extends to “transacting in, providing financing for, or otherwise dealing in new debt—issued on or after July 16, 2014—of greater than 90 days maturity by, on behalf of, or for the benefit of the persons operating in Russia’s energy sector named under the Directive 2, their property, or their interests in property.” OFAC further added that the Directive 2 prohibitions apply to “all transactions involving new debt with a maturity of longer than 90 days; all financing in support of such new debt; and any dealing in, including provision of services in support of, such new debt.”

OFAC further clarified that:

  1. the prohibitions in both directives extend to rollover of existing debt, if such rollover results in the creation of new debt with a maturity of longer than 90 days;
  2. transacting in, providing financing for, or otherwise dealing in any debt or equity issued prior to July 16, 2104 is permissible;
  3. transacting in, providing financing for, or otherwise dealing in debt instruments with maturities of 90 days or less is permissible;
  4. transacting in, providing financing for, or otherwise dealing in new equity instruments for entities operating in the Russian energy sector identified in Directive 2  is permissible; and
  5. U.S. financial institutions may continue to maintain correspondent accounts and process U.S. dollar-clearing transactions for the persons identified in the directives, so long as those activities do not involve transacting in, providing financing for, or otherwise dealing in prohibited transaction types identified by these directives.

Finally, OFAC issued a general license authorizing transactions by U.S. persons, wherever located, and transactions within the United States involving derivative products whose value is linked to an underlying asset that constitutes debt or equity, as detailed above.

SDN Designations. In addition to the sectoral sanctions detailed above, OFAC also added the individuals and entities set forth in Appendix 3 to the SDN list pursuant to Executive Orders 13660 (Mar. 6, 2014) and 13661 (Mar. 17, 2014). As a result, the property and interests in property of such individuals and entities, as well as entities that are 50 percent or more owned, directly or indirectly, by such persons, that are in the United States, that come within the United States, or that are or come within the possession or control of any U.S. person, are blocked.

Entity List Additions. In addition to the actions taken by OFAC, BIS has added the same eleven entities designated by OFAC as SDNs to the Entity List under the Export Administration Regulations (“EAR”), but has identified them in the manner set forth in Appendix 4. Generally, the Entity List consists of entities determined by BIS to present an unacceptable risk of diversion into programs relating to the development of weapons of mass destruction, terrorism, or other activities contrary to U.S. national security or foreign policy interests. As a result of the Entity List designation, BIS has imposed a license requirement for the export, re-export or in-country transfer of items subject to the EAR by any person to these entities, with the presumption of denial.   

European Union Sanctions
During the special meeting on 16 July, the European Council agreed to expand restrictive measures with a view to targeting individuals and entities that are materially and financially supporting actions undermining or threatening Ukraine’s sovereignty, territorial integrity and independence. The legal acts implementing this decision were published on 19 July. For the moment, however, no new entities or individuals have been added to the list of entities and individuals subject to restrictive measures. The European Council has set a deadline of the end of July by which entities and individuals, including from Russia, should be identified and listed under the new criteria. The EU will also consider the possibility of targeting entities and individuals who actively provide material or financial support to the Russian decision-makers responsible for the annexation of Crimea or the destabilisation of Eastern-Ukraine.

The European Council also agreed to ask the European Investment Bank to suspend new lending for Russia and to seek suspension of lending to Russia by the European Bank for Reconstruction and Development. In addition, the European Council asked the Commission to consider suspending some of the cooperation programmes that do not deal exclusively with cross-border cooperation and civil society.

Further, in view of the illegal annexation of Crimea and Sevastopol by Russia, the European Commission and the European External Action Service will provide proposals on measures restricting European investment in Crimea. The European Council expects that international financial institutions will refrain from financing projects that explicitly or implicitly recognise the illegal annexation.

The Foreign Affairs Ministers of the EU Member States are meeting on 22 July and it is very likely that further decisions regarding sanctions against Russia will be taken on that day.

In further recent developments since our last alert, on 17 July the European Parliament passed a non binding resolution on the situation in Ukraine. It called for a collective ban on the sale of arms to Russia and urged such implementation until the situation in eastern Ukraine has normalised. Both the European Parliament and the European Council warned that any further steps by Russia to destabilise Ukraine will lead to additional and far-reaching consequences for EU-Russian relations.

On 11 July, the Council agreed, in view of the gravity of the situation in Ukraine, to add 11 new individuals to the list of persons subject to an asset freeze, a prohibition against making funds or economic resources available and travel restrictions. The individuals, together with the reasons for their inclusion of persons subject to restrictive measures as described in the EU legislation (published on 12 July), are listed in Appendix 5.

It was also announced on 7 July that Liechtenstein, Norway, Iceland, Montenegro, Albania, as well as Ukraine will ensure that their national policies conform to EU sanctions against Russia.

Appendix 1
BANK FOR DEVELOPMENT AND FOREIGN ECONOMIC AFFAIRS (VNESHECONOMBANK) STATE CORPORATION (a.k.a. BANK RAZVITIYA I VNESHNEEKONOMICHESKOI DEYATELNOSTI (VNESHEKONOMBANK) GOSUDARSTVENNAYA KORPORATSIYA; a.k.a. VNESHECONOMBANK; a.k.a. "VEB"), 9 Akademika Sakharova prospekt, Moscow 107996, Russia; SWIFT/BIC BFEA RU MM; Website http://www.veb.ru; Email Address info@veb.ru; BIK (RU) 044525060 [UKRAINE-EO13662]

BANK RAZVITIYA I VNESHNEEKONOMICHESKOI DEYATELNOSTI (VNESHEKONOMBANK) GOSUDARSTVENNAYA KORPORATSIYA (a.k.a. BANK FOR DEVELOPMENT AND FOREIGN ECONOMIC AFFAIRS (VNESHECONOMBANK) STATE CORPORATION; a.k.a. VNESHECONOMBANK; a.k.a. "VEB"), 9 Akademika Sakharova prospekt, Moscow 107996, Russia; SWIFT/BIC BFEA RU MM; Website http://www.veb.ru; Email Address info@veb.ru; BIK (RU) 044525060 [UKRAINE-EO13662]

GAZPROMBANK GAS INDUSTRY OJSC (a.k.a. GAZPROMBANK OAO; a.k.a. GAZPROMBANK OJSC; a.k.a. GAZPROMBANK OPEN JOINT STOCK COMPANY; a.k.a. GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. GPB, OAO; a.k.a. GPB, OJSC), 16, Building 1, Nametkina St., Moscow 117420, Russia; 63, Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC GAZPRUMM; Website www.gazprombank.ru; Email Address mailbox@gazprombank.ru; Registration ID 1027700167110; Tax ID No. 7744001497; Government Gazette Number 09807684 [UKRAINE-EO13662]

GAZPROMBANK OAO (a.k.a. GAZPROMBANK GAS INDUSTRY OJSC; a.k.a. GAZPROMBANK OJSC; a.k.a. GAZPROMBANK OPEN JOINT STOCK COMPANY; a.k.a. GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. GPB, OAO; a.k.a. GPB, OJSC), 16, Building 1, Nametkina St., Moscow 117420, Russia; 63, Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC GAZPRUMM; Website www.gazprombank.ru; Email Address mailbox@gazprombank.ru; Registration ID 1027700167110; Tax ID No. 7744001497; Government Gazette Number 09807684 [UKRAINE-EO13662]

GAZPROMBANK OJSC (a.k.a. GAZPROMBANK GAS INDUSTRY OJSC; a.k.a. GAZPROMBANK OAO; a.k.a. GAZPROMBANK OPEN JOINT STOCK COMPANY; a.k.a. GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. GPB, OAO; a.k.a. GPB, OJSC), 16, Building 1, Nametkina St., Moscow 117420, Russia; 63, Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC GAZPRUMM; Website www.gazprombank.ru; Email Address mailbox@gazprombank.ru; Registration ID 1027700167110; Tax ID No. 7744001497; Government Gazette Number 09807684 [UKRAINE-EO13662]

GAZPROMBANK OPEN JOINT STOCK COMPANY (a.k.a. GAZPROMBANK GAS INDUSTRY OJSC; a.k.a. GAZPROMBANK OAO; a.k.a. GAZPROMBANK OJSC; a.k.a. GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. GPB, OAO; a.k.a. GPB, OJSC), 16, Building 1, Nametkina St., Moscow 117420, Russia; 63, Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC GAZPRUMM; Website www.gazprombank.ru; Email Address mailbox@gazprombank.ru; Registration ID 1027700167110; Tax ID No. 7744001497; Government Gazette Number 09807684 [UKRAINE-EO13662]

GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO (a.k.a. GAZPROMBANK GAS INDUSTRY OJSC; a.k.a. GAZPROMBANK OAO; a.k.a. GAZPROMBANK OJSC; a.k.a. GAZPROMBANK OPEN JOINT STOCK COMPANY; a.k.a. GPB, OAO; a.k.a. GPB, OJSC), 16, Building 1, Nametkina St., Moscow 117420, Russia; 63, Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC GAZPRUMM; Website www.gazprombank.ru; Email Address mailbox@gazprombank.ru; Registration ID 1027700167110; Tax ID No. 7744001497; Government Gazette Number 09807684 [UKRAINE-EO13662]

GPB, OAO (a.k.a. GAZPROMBANK GAS INDUSTRY OJSC; a.k.a. GAZPROMBANK OAO; a.k.a. GAZPROMBANK OJSC; a.k.a. GAZPROMBANK OPEN JOINT STOCK COMPANY; a.k.a. GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. GPB, OJSC), 16, Building 1, Nametkina St., Moscow 117420, Russia; 63, Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC GAZPRUMM; Website www.gazprombank.ru; Email Address mailbox@gazprombank.ru; Registration ID 1027700167110; Tax ID No. 7744001497; Government Gazette Number 09807684 [UKRAINE-EO13662]

GPB, OJSC (a.k.a. GAZPROMBANK GAS INDUSTRY OJSC; a.k.a. GAZPROMBANK OAO; a.k.a. GAZPROMBANK OJSC; a.k.a. GAZPROMBANK OPEN JOINT STOCK COMPANY; a.k.a. GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. GPB, OAO), 16, Building 1, Nametkina St., Moscow 117420, Russia; 63, Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC GAZPRUMM; Website www.gazprombank.ru; Email Address mailbox@gazprombank.ru; Registration ID 1027700167110; Tax ID No. 7744001497; Government Gazette Number 09807684 [UKRAINE-EO13662]

VNESHECONOMBANK (a.k.a. BANK FOR DEVELOPMENT AND FOREIGN ECONOMIC AFFAIRS (VNESHECONOMBANK) STATE CORPORATION; a.k.a. BANK RAZVITIYA I VNESHNEEKONOMICHESKOI DEYATELNOSTI (VNESHEKONOMBANK) GOSUDARSTVENNAYA KORPORATSIYA; a.k.a. "VEB"), 9 Akademika Sakharova prospekt, Moscow 107996, Russia; SWIFT/BIC BFEA RU MM; Website http://www.veb.ru; Email Address info@veb.ru; BIK (RU) 044525060 [UKRAINE-EO13662]

"VEB" (a.k.a. BANK FOR DEVELOPMENT AND FOREIGN ECONOMIC AFFAIRS (VNESHECONOMBANK) STATE CORPORATION; a.k.a. BANK RAZVITIYA I VNESHNEEKONOMICHESKOI DEYATELNOSTI (VNESHEKONOMBANK) GOSUDARSTVENNAYA KORPORATSIYA; a.k.a. VNESHECONOMBANK), 9 Akademika Sakharova prospekt, Moscow 107996, Russia; SWIFT/BIC BFEA RU MM; Website http://www.veb.ru; Email Address info@veb.ru; BIK (RU) 044525060 [UKRAINE-EO13662]       

Appendix 2
FINANSOVO-INVESTITSIONNAYA KOMPANIYA NOVAFININVEST OAO (a.k.a. NOVATEK; a.k.a. OAO NOVATEK), 2, Udaltsova Street, Moscow 119415, Russia; 22 A, Pobedy Street, Tarko-Sale, Yamalo-Nenets Autonomous District 629580, Russia; 22a Pobedy ul., Tarko-Sale, Purovski raion, Tyumenskaya Oblast 629850, Russia; Email Address novatek@novatek.ru; Registration ID 1026303117642 (Russia); Government Gazette Number 33556474 (Russia) [UKRAINE-EO13662].

NOVATEK (a.k.a. FINANSOVO-INVESTITSIONNAYA KOMPANIYA NOVAFININVEST OAO; a.k.a. OAO NOVATEK), 2, Udaltsova Street, Moscow 119415, Russia; 22 A, Pobedy Street, Tarko-Sale, Yamalo-Nenets Autonomous District 629580, Russia; 22a Pobedy ul., Tarko-Sale, Purovski raion, Tyumenskaya Oblast 629850, Russia; Email Address novatek@novatek.ru; Registration ID 1026303117642 (Russia); Government Gazette Number 33556474 (Russia) [UKRAINE-EO13662].

OAO NOVATEK (a.k.a. FINANSOVO-INVESTITSIONNAYA KOMPANIYA NOVAFININVEST OAO; a.k.a. NOVATEK), 2, Udaltsova Street, Moscow 119415, Russia; 22 A, Pobedy Street, Tarko-Sale, Yamalo-Nenets Autonomous District 629580, Russia; 22a Pobedy ul., Tarko-Sale, Purovski raion, Tyumenskaya Oblast 629850, Russia; Email Address novatek@novatek.ru; Registration ID 1026303117642 (Russia); Government Gazette Number 33556474 (Russia) [UKRAINE-EO13662].

OAO ROSNEFT OIL COMPANY (a.k.a. OIL COMPANY ROSNEFT; a.k.a. OJSC ROSNEFT OIL COMPANY; a.k.a. OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY; a.k.a. ROSNEFT; a.k.a. ROSNEFT OIL COMPANY), 26/1 Sofiyskaya Embankment, Moscow 115035, Russia; Website www.rosneft.com; alt. Website www.rosneft.ru; Email Address postman@rosneft.ru; Registration ID 1027700043502 (Russia); Tax ID No. 7706107510 (Russia); Government Gazette Number 00044428 (Russia) [UKRAINE-EO13662].

OIL COMPANY ROSNEFT (a.k.a. OAO ROSNEFT OIL COMPANY; a.k.a. OJSC ROSNEFT OIL COMPANY; a.k.a. OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY; a.k.a. ROSNEFT; a.k.a. ROSNEFT OIL COMPANY), 26/1 Sofiyskaya Embankment, Moscow 115035, Russia; Website www.rosneft.com; alt. Website www.rosneft.ru; Email Address postman@rosneft.ru; Registration ID 1027700043502 (Russia); Tax ID No. 7706107510 (Russia); Government Gazette Number 00044428 (Russia) [UKRAINE-EO13662].

OJSC ROSNEFT OIL COMPANY (a.k.a. OAO ROSNEFT OIL COMPANY; a.k.a. OIL COMPANY ROSNEFT; a.k.a. OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY; a.k.a. ROSNEFT; a.k.a. ROSNEFT OIL COMPANY), 26/1 Sofiyskaya Embankment, Moscow 115035, Russia; Website www.rosneft.com; alt. Website www.rosneft.ru; Email Address postman@rosneft.ru; Registration ID 1027700043502 (Russia); Tax ID No. 7706107510 (Russia); Government Gazette Number 00044428 (Russia) [UKRAINE-EO13662].

OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY (a.k.a. OAO ROSNEFT OIL COMPANY; a.k.a. OIL COMPANY ROSNEFT; a.k.a. OJSC ROSNEFT OIL COMPANY; a.k.a. ROSNEFT; a.k.a. ROSNEFT OIL COMPANY), 26/1 Sofiyskaya Embankment, Moscow 115035, Russia; Website www.rosneft.com; alt. Website www.rosneft.ru; Email Address postman@rosneft.ru; Registration ID 1027700043502 (Russia); Tax ID No. 7706107510 (Russia); Government Gazette Number 00044428 (Russia) [UKRAINE-EO13662].

ROSNEFT (a.k.a. OAO ROSNEFT OIL COMPANY; a.k.a. OIL COMPANY ROSNEFT; a.k.a. OJSC ROSNEFT OIL COMPANY; a.k.a. OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY; a.k.a. ROSNEFT OIL COMPANY), 26/1 Sofiyskaya Embankment, Moscow 115035, Russia; Website www.rosneft.com; alt. Website www.rosneft.ru; Email Address postman@rosneft.ru; Registration ID 1027700043502 (Russia); Tax ID No. 7706107510 (Russia); Government Gazette Number 00044428 (Russia) [UKRAINE-EO13662].

ROSNEFT OIL COMPANY (a.k.a. OAO ROSNEFT OIL COMPANY; a.k.a. OIL COMPANY ROSNEFT; a.k.a. OJSC ROSNEFT OIL COMPANY; a.k.a. OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY; a.k.a. ROSNEFT), 26/1 Sofiyskaya Embankment, Moscow 115035, Russia; Website www.rosneft.com; alt. Website www.rosneft.ru; Email Address postman@rosneft.ru; Registration ID 1027700043502 (Russia); Tax ID No. 7706107510 (Russia); Government Gazette Number 00044428 (Russia) [UKRAINE-EO13662].

Appendix 3
BESEDA, Sergey (a.k.a. BESEDA, Sergei; a.k.a. BESEDA, Sergei Orestovoch); DOB 1954; Commander of the Fifth Service of the FSB; Commander of the Service for Operational Information and International Communications of the FSB; FSB Colonel General; Colonel-General (individual) [UKRAINE2]

BORODAI, Aleksandr (a.k.a. BORODAI, Alexander); DOB 25 Jul 1972; nationality Russia (individual) [UKRAINE]

NEVEROV, Sergei Ivanovich (a.k.a. NEVEROV, Sergei; a.k.a. NEVEROV, Sergey); DOB 21 Dec 1961; POB Tashtagol, Russia; Deputy Chairman of the State Duma of the Russian Federation; Member of the State Duma Committee on Housing Policy and Housing and Communal Services (individual) [UKRAINE2]

SAVELYEV, Oleg Genrikhovich; DOB 27 Oct 1965; POB St. Petersburg, Russia; Minister for Crimean Affairs (individual) [UKRAINE2]

SHCHEGOLEV, Igor (a.k.a. SHCHYOGOLEV, Igor Olegovich); DOB 10 Nov 1965; POB Vinnitsa, Ukraine; alt. POB Vinnytsia, Ukraine; Aide to the President of the Russian Federation (individual) [UKRAINE2]

DONETSK PEOPLE'S REPUBLIC, Donetsk Region, Ukraine [UKRAINE]
FEDERAL STATE UNITARY ENTERPRISE STATE RESEARCH AND PRODUCTION ENTERPRISE BAZALT (a.k.a. FEDERAL STATE UNITARY ENTERPRISE, STATE RESEARCH AND PRODUCTION ENTERPRISE BAZALT; a.k.a. FSUE SRPE BAZALT; a.k.a. STATE RESEARCH AND PRODUCTION ENTERPRISE BAZALT), 32 Velyaminovskaya, Moscow 105318, Russia; Website www.bazalt.ru; Email Address moscow@bazalt.ru [UKRAINE2]

FEODOSIYA ENTERPRISE (a.k.a. FEODOSIA OIL PRODUCTS SUPPLY CO.; a.k.a. FEODOSIYA ENTERPRISE ON PROVIDING OIL PRODUCTS; a.k.a. FEODOSIYSKE COMPANY FOR THE OIL; a.k.a. THEODOSIYA OIL TERMINAL), Feodosiya, Geologicheskaya str. 2, Crimea 98107, Ukraine; Feodosia, Str. Geological 2, Crimea 98107, Ukraine [UKRAINE]

JOINT STOCK COMPANY CONCERN RADIO-ELECTRONIC TECHNOLOGIES (a.k.a. CONCERN RADIO-ELECTRONIC TECHNOLOGIES; a.k.a. "KRET"), 20/1 Korp. 1 ul. Goncharnaya, Moscow 109240, Russia; Website http://www.kret.com; Registration ID 1097746084666 [UKRAINE2]

JOINT STOCK COMPANY CONCERN SOZVEZDIE (a.k.a. JSC CONCERN SOZVEZDIE), 14 Plekhanovskaya Street, Voronezh, Russia; 14 ul. Plekhanovskaya, Voronezh, Voronezhskaya obl. 394018, Russia; Registration ID 1053600445337 [UKRAINE2]

JOINT STOCK COMPANY MILITARY-INDUSTRIAL CORPORATION NPO MASHINOSTROYENIA (a.k.a. JOINT STOCK COMPANY MILITARY INDUSTRIAL CONSORTIUM NPO MASHINOSTROYENIA; a.k.a. JSC MIC NPO MASHINOSTROYENIA; a.k.a. MIC NPO MASHINOSTROYENIA JSC; a.k.a. MIC NPO MASHINOSTROYENIYA JSC; a.k.a. MILITARY INDUSTRIAL CORPORATION NPO MASHINOSTROENIA OAO; a.k.a. OPEN JOINT STOCK COMPANY MILITARY INDUSTRIAL CORPORATION SCIENTIFIC AND PRODUCTION MACHINE BUILDING ASSOCIATION; a.k.a. VOENNO-PROMYSHLENNAYA KORPORATSIYA NAUCHNO-PROIZVODSTVENNOE OBEDINENIE MASHINOSTROENIYA OAO; a.k.a. VPK NPO MASHINOSTROENIYA), 33, Gagarina St., Reutov-town, Moscow Region 143966, Russia; 33 Gagarin Street, Reutov, Moscow Region 143966, Russia; 33 Gagarina ul., Reutov, Moskovskaya obl 143966, Russia; Website www.npomash.ru; Email Address export@npomash.ru; alt. Email Address vpk@npomash.ru; Registration ID 1075012001492 (Russia); Tax ID No. 5012039795 (Russia); Government Gazette Number 07501739 (Russia) [UKRAINE2]

JOINT-STOCK COMPANY CONCERN ALMAZ-ANTEY (a.k.a. ALMAZ-ANTEY CORP; a.k.a. ALMAZ-ANTEY DEFENSE CORPORATION; a.k.a. ALMAZ-ANTEY JSC; f.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO KONTSERN PVO ALMAZ ANTEI), 41 ul.Vereiskaya, Moscow 121471, Russia; Website almaz-antey.ru; Email Address antey@almaz-antey.ru [UKRAINE2]

KALASHNIKOV CONCERN (a.k.a. CONCERN KALASHNIKOV; a.k.a. IZHEVSKIY MASHINOSTROITEL'NYI ZAVOD OAO; f.k.a. IZHMASH R&D CENTER; f.k.a. JSC NPO IZHMASH; f.k.a. NPO IZHMASH OAO; a.k.a. OJSC CONCERN KALASHNIKOV; f.k.a. OJSC IZHMASH; f.k.a. SCIENTIFIC PRODUCTION ASSOCIATION IZHMASH JOINT STOCK COMPANY), 3, Derjabin Pr., Izhevsk, Udmurt Republic 426006, Russia; Registration ID 1111832003018 [UKRAINE2]

KONSTRUKTORSKOE BYURO PRIBOROSTROENIYA OTKRYTOE AKTSIONERNOE OBSHCHESTVO (a.k.a. INSTRUMENT DESIGN BUREAU; a.k.a. JSC KBP INSTRUMENT DESIGN BUREAU; a.k.a. KBP INSTRUMENT DESIGN BUREAU; a.k.a. KBP INSTRUMENT DESIGN BUREAU JOINT STOCK COMPANY; a.k.a. "KBP OAO"), 59 Shcheglovskaya Zaseka ul., Tula 300001, Russia; Website www.kbptula.ru; Email Address kbkedr@tula.net; Registration ID 1117154036911 (Russia); Government Gazette Number 07515747 (Russia) [UKRAINE2]

LUHANSK PEOPLE'S REPUBLIC (a.k.a. LUGANSK PEOPLE'S REPUBLIC; a.k.a. PEOPLE'S REPUBLIC OF LUHANSK), Luhansk Region, Ukraine [UKRAINE]

URALVAGONZAVOD (a.k.a. NAUCHNO-PROIZVODSTVENNAYA KORPORATSIYA URALVAGONZAVOD OAO; a.k.a. NPK URALVAGONZAVOD; a.k.a. NPK URALVAGONZAVOD OAO; a.k.a. OJSC RESEARCH AND PRODUCTION CORPORATION URALVAGONZAVOD; a.k.a. RESEARCH AND PRODUCTION CORPORATION URALVAGONZAVOD; a.k.a. RESEARCH AND PRODUCTION CORPORATION URALVAGONZAVOD OAO; a.k.a. URALVAGONZAVOD CORPORATION; a.k.a. "UVZ"), 28, Vostochnoye shosse, Nizhni Tagil, Sverdlovsk region 622007, Russia; 28 Vostochnoe shosse, Nizhni Tagil, Sverdlovskaya oblast 622007, Russia; 40, Bolshaya Yakimanka Street, Moscow 119049, Russia; Vistochnoye Shosse, 28, Nizhny Tagil 622007, Russia; Website http://www.uvz.ru/; alt. Website http://uralvagonzavod.com/; Email Address web@uvz.ru [UKRAINE2]

Appendix 4
Donetsk People’s Republic
Feodosia Enterprise
JSC Concern Radio-Electronic Technologies
JSC Concern Sozvezdie
JSCC Almaz-Antey
Kalashnikov Concern
KBP Instrument Design Bureau
Luhansk People’s Republic
MIC NOP Mashinostroyenia
Research and Production Corporation “UralVagonZavod”
State Research and Production Enterprise “Bazalt”

Appendix 5

  1. Aleksandr Yurevich BORODAI (????????? ??????? ???????) (DOB: 25.7.1972 in Moscow) - So called ‘Prime Minister of People's Republic of Donetsk’. Responsible for the separatist ‘governmental’ activities of the so called ‘government of the Donetsk People's Republic’ (e.g. on 8 July stated ‘our military is conducting a special operation against the Ukrainian “fascists”’), Signatory of the Memorandum of Understanding on ‘Novorossiya union’.
  2. Alexander KHODAKOVSKY (????????? ????????? ???????????) - So called ‘Minister of Security of People's Republic of Donetsk’. Responsible for the separatist security activities of the so called ‘government of the Donetsk People's Republic’.
  3. Alexandr Aleksandrovich KALYUSSKY, (????????? ????????????? ?????????) - So called ‘de facto Deputy Prime Minister for Social Affairs of DPR’. Responsible for the separatist ‘governmental’ activities of the so called ‘government of the Donetsk People's Republic’.
  4. Alexander KHRYAKOV - So called ‘Information and Mass Communications Minister of DPR’. Responsible for the pro-separatist propaganda activities of the so called ‘government of the Donetsk People's Republic’.
  5. Marat BASHIROV - So called ‘Prime Minister of the Council of Ministers of the People's Republic of Luhansk, confirmed on 8 Jul’. Responsible for the separatist ‘governmental’ activities of the so called ‘government of the People's Republic of Luhansk’.
  6. Vasyl NIKITIN - So called ‘Vice Prime Minister of the Council of Ministers of the People's Republic of Luhansk’, (used to be the so called ‘Prime Minister of the People's Republic of Luhansk’, and former spokesman of the ‘Army of the Southeast’). Responsible for the separatist ‘governmental’ activities of the so called ‘government of the People's Republic of Luhansk’ Responsible for the statement of the Army of the Southeast that the Ukrainian presidential elections in the ‘People's Republic of Luhansk’ cannot take place due to the ‘new’ status of the region.
  7. Aleksey KARYAKIN (??????? ???????) (1979) - So called ‘Supreme Council Chair of the People's Republic of Luhansk’. Responsible for the separatist ‘governmental’ activities of the ‘Supreme Council’, responsible for asking the Russian Federation to recognize the independence of ‘People's Republic of Luhansk’ Signatory of the Memorandum of Understanding on the ‘Novorossiya union’.
  8. Yurij IVAKIN (???? ??????) - So called ‘Minister of Internal Affairs of the People's Republic of Luhansk’.Responsible for the separatist ‘governmental’ activities of the so called ‘government of the People's Republic of Luhansk’.
  9. Igor PLOTNITSKY - So called ‘Defence Minister of the People's Republic of Luhansk’. Responsible for the separatist ‘governmental’ activities of the so called ‘government of the People's Republic of Luhansk’.
  10. Nikolay KOZITSYN (June 20, 1956 in Donetsk region) - Commander of Cossack forces.Responsible for commanding separatists in Eastern Ukraine fighting against the Ukrainian government forces.
  11. Oleksiy MOZGOVY (??????? ????????) - One of the leaders of armed groups in Eastern Ukraine. Responsible for training separatists to fight against the Ukrainian government forces.

 

Topics:  Banking Sector, BIS, Energy Sector, OFAC, Russia, Sanctions, SDN List, SSIL, U.S. Treasury, Ukraine

Published In: General Business Updates, Elections & Politics Updates, Energy & Utilities Updates, Finance & Banking Updates, International Trade Updates

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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