Crisis in the Crimea: Sanctions Update

by Reed Smith

United States further measures

In response to the Russian Federation’s continued actions in southern and eastern Ukraine, the United States added seventeen entities and seven Russian officials and related persons to its list of Ukraine-related sanctioned persons yesterday. United States persons are prohibited from continuing or entering into transactions with entities and individuals specifically designated and entities that are 50% or more owned by a sanctioned entity or individual.

As part of the sanctions, the United States Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the addition of thirteen companies to the BIS Entity List and expanded its export restrictions on items subject to the Export Administration Regulations (EAR). The entities added to the BIS Entity List are: Stroytransgaz Holding; Volga Group; Aquanika, Avia Group LLC, Avia Group Nord LLC, CJSC Zest, Sakhatrans LLC, Stroygazmontazh, Stroytransgaz Group, Stroytransgaz LLC, Stroytransgaz-M LLC, Stroytransgaz OJSC, and Transoil. These designations impose a license requirement, with a presumption of denial to the entities, for exports, re-exports or other foreign transfers of items subject to the EAR.

Both BIS and State Department’s Directorate of Defense Trade Controls (DDTC) published statements that they will deny any pending applications for licenses to export or re-export to Russia or Crimea, any high technology item that contributes to Russia's military capabilities regulated under the EAR or the United States Munitions List as a defense article or service. BIS and DDTC are undertaking case-by-case evaluations of all current licenses and pending license applications and will revoke or deny any applications or export licenses it deems to meet these conditions.

The following is the list of newly added Ukraine-related sanctioned individuals and entities to OFAC’s Specially Designated Nationals 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].
  • 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; alt. Website; Email Address; Registration ID 1075247000036 [UKRAINE2].
  • AVIA GROUP LLC (a.k.a. AVIA GROUP LTD), Terminal Aeroport Sheremetyevo Khimki, 141400 Moskovskaya obl., Russia; Website [UKRAINE2].
  • AVIA GROUP NORD LLC, 17 A, Stratoyava St., Saint Petersburg, Russia; Website [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; 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; 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; 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; Email Address [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; alt. Website; Email Address [UKRAINE2].
  • STROYTRANSGAZ GROUP (a.k.a. STROYTRANSGAZ; a.k.a. "STG GROUP"), 3 Begovaya Street, Building #1, Moscow 125284, Russia; Website [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; alt. Website; Email Address;  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].

In the energy and financial services sectors, it should be noted that Igor Sechin, President and Chairman of the Management Board of the oil company Rosneft, has been targeted, though Rosneft itself is not subject to the sanctions. Gennady Timchenko, who was previously listed in the last round of sanctions on 20 March 2014, has been targeted again through the listing of the Volga Group, and a number of its subsidiaries, which includes Russia’s biggest private railway carrier of oil and oil products, Transoil. Other additions to the list include SMP Bank, Investcapitalbank and oil and gas contractor, Stroygazmontazh, all of which are controlled by the Rotenberg brothers, who were listed on 20 March 2014. Also targeted are three subsidiaries (Zest Leasing, Sobinbank, LLC IC Abros) of Bank Rossiya, previously listed in the last round of sanctions.

European Union further measures

Having joined in criticising the Russian Federation’s continued actions in southern and eastern Ukraine, effective today the Council of the European Union has added fifteen persons to the list of those subject to a travel ban and a freeze on their assets within the European Union. They are:

  • KOZAK, Dmitry Nikolayevich; DOB 7 Nov 1958; POB Kirovohrad, Ukrainian SSR; Deputy Prime Minister; responsible for overseeing the integration of the annexed Autonomous Republic of Crimea into the Russian Federation.
  • BELAVENTSEV, Oleg Yevgenyvich; DOB 15 Sep 1949; POB 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.
  • SAVELYEV, Oleg Genrikhovich; DOB 27 Oct 1965; POB Leningrad; Minister for Crimean Affairs; responsible for the integration of the annexed Autonomous Republic of Crimea into the Russian Federation.
  • MENYAILO, Sergei Ivanovich; DOB 22 Aug 1960; POB Alagir, North-Ossetian Autonomous SSR, RSFSR; Acting Governor of the Ukrainian annexed city of Sevastopol.
  • KOVATIDI, Olga Fedorovna; DOB 7 May 1962; POB Simferopol, Ukrainian SSR; Member of the Russian Federation Council from the annexed Autonomous Republic of Crimea.
  • SHVETSOVA, Ludmila Ivanovna; DOB 24 Sept 1949; POB 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. 
  • NEVEROV, Sergei Ivanovich; DOB 21 Dec 1961; POB 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.
  • SERGUN, Igor Dmitrievich; DOB 28 March 1957; POB not provided; 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.
  • GERASIMOV, Valery Vasilevich; DOB 8 Sept 1955; POB 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.
  • PROKOPIV, German; DOB not provided; POB not provided; 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’.
  • BOLOTOV, Valeriy; DOB not provided; POB not provided; 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.
  • PURGIN, Andriy; DOB not provided; POB not provided; head of the ‘Donetsk Republic’, active participant and organizer of separatist actions; coordinator of actions of the ‘Russian tourists’ in Donetsk; co-founder of a ‘Civic Initiative of Donbass for the Eurasian Union’.
  • PUSHYLIN, Denys; DOB not provided; POB 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.
  • GENNADEVICH, Tsyplakov Sergey; DOB not provided; POB not provided; 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.
  • STRELKOV, Igor (STRIELKOV, Ihor); DOB not provided; POB not provided; 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.

This is far short of Iran-style “stage 3” measures against, for example, the entire banking system or the mining, oil and gas industries. It is milder than that of the United States, in that the European Union has not targeted any business leaders or entities but has confined it focus to State officials, members of the intelligence community and separatist leaders.


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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