Mr. Sanctions

Month: December 2025

  • OFAC Russia-related General License 131 gets updated

    OFAC today issued a notice announcing the release of Russia-related General License 131A “Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities.” Here’s a simplified version:

    What is this document?

    This is a permission slip (General License) issued by the U.S. Treasury Department on December 10, 2025. It updates and replaces the previous “General License No. 131.”

    What does it allow?

    It temporarily authorizes two main types of activities related to Lukoil International GmbH (LIG), which is the international arm of the Russian oil company Lukoil:

    1. Negotiating a Sale: Companies are allowed to negotiate and sign “contingent” contracts to buy LIG (or its subsidiaries) from Lukoil.
      • Note: “Contingent” means the deal cannot be finalized or executed yet. You can sign the paperwork, but the actual transfer of ownership requires separate, future approval.
    2. Keeping the Lights On: It allows for the necessary transactions to keep LIG’s operations running (maintenance) or to wind them down safely. This ensures the business doesn’t collapse while potential sales are being discussed.

    When does it expire?

    These activities are authorized until January 17, 2026 (specifically at 12:01 a.m. EST).

    What does it NOT allow?

    • It does not allow the actual completion of the sale or transfer of assets (only the negotiation and signing of the initial agreement).
    • It does not unblock frozen funds or property, except for the specific maintenance tasks allowed.
    • It does not allow payments to other sanctioned (blocked) persons unless specifically authorized.

    Why was this issued?

    This license essentially creates a window of time for Lukoil to potentially divest (sell off) its international business to non-sanctioned parties, while preventing the international branch from failing in the meantime.

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  • Follow the leader: OFSI also removes Munir Al Qubaysi from Iraq sanctions

    Based on the Office of Financial Sanctions Implementation (OFSI) Financial Sanctions Notice for Iraq, dated 10/12/2025, there is one section of Delistings.

    Individual

    • AL QUBAYSI, Munir
    • Group ID: 8278
    • Name (non-Latin script): منير القبيسي
    • DOB: –/–/1966.
    • POB: Heet, Iraq
    • Good quality a.k.a: (1) AL-KUBAISI, Muneer (2) AL-KUBAYSI, Munir (3) AWAD, Munir (4) AWAD, Munir, A, Mamduh.
    • Nationality: Iraq
    • Address: Syria.
    • Other Information: (UK Sanctions List Ref): IRQ0135. (UN Ref): IQi.074.
    • Listed on: 05/05/2004
    • UK Sanctions List Date Designated: 26/04/2004
    • Last Updated: 10/12/2025

    Supplemental Information:

    • Munir Al Qubaysi was removed from the UN Security Council’s 1518 Sanctions List (Iraq) on December 9, 2025, which precipitated his removal from the UK list on December 10, 2025.
    • He was originally listed by the UN on April 26, 2004, under the reference number IQi.074.
    • The UN listing linked him to the entity Al-Huda State Company for Religious Tourism (Entity reference IQe.204).
    • Al-Huda State Company for Religious Tourism was identified as a commercial front for the Iraqi Intelligence Service under the former regime, allegedly used to skim funds from tourism packages for Iranian pilgrims.
    • He has been designated under various aliases including Munir Awad and Munir Mamduh Awad.
    • He remains listed on the US OFAC Specially Designated Nationals (SDN) list under the program IRAQ2 as of the latest available search data, with the same identifying details (POB: Heet, Iraq; DOB: 1966).

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  • UN 1518 Sanctions Committee removes 1 person from Iraq sanctions

    Note: I do not have a prompt yet to reformat UN designations. Given the inconsistency of the format (note how the “a.k.a.” after “Low quality” isn’t bolded like the one after “Good quality”), I may not.

    SC/16240

    9 December 2025

    Security Council 1518 Sanctions Committee Removes One Entry from Its Sanctions List

    On 9 December 2025, the Security Council Committee established pursuant to resolution 1518 (2003) removed the following entry from its Sanctions List of individuals and entities.

    A. Individuals

    IQi.074 Name: 1: MUNIR 2: AL QUBAYSI 3: na 4: na
    Name (original script): منير القبيسي
    Title: na Designation: na DOB: 1966 POB: Heet, Iraq Good quality a.k.a.: a) Munir Al-Kubaysi b)Muneer Al-Kubaisi c) Munir Awad d) Munir A Mamduh. Awad Low quality a.k.a.: na Nationality: Iraq Passport no: na National identification no: na Address: Syrian Arab Republic Listed on: 26 Apr. 2004 Other information:  No link available

    Press releases concerning changes to the Committee’s Sanctions List may be found in the “Press Releases” section on the Committee’s website at the following URL:  https://main.un.org/securitycouncil/en/sanctions/1518/press-releases.

    The updated version of the Committee’s Sanctions List, available in HTML, PDF and XML format, may be found at the following URL:  https://main.un.org/securitycouncil/en/sanctions/1518/materials.

    The United Nations Security Council Consolidated List is also updated following all changes made to the Committee’s Sanctions List and is accessible at the following URL:  https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list.

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  • December 9, 2025: OFAC Sudan-related Designations; Russia-related Designations Removals

    Treasury Press Release: Treasury Sanctions Transnational Network Recruiting Colombians to Fight in Sudan’s Civil War

    From today’s OFAC release:

    The additions to the Sudan program:

    The following individuals have been added to OFAC’s SDN List:

    [SUDAN-EO14098] – Executive Order 14098 (Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition)

    • DUQUE BOTERO, Mateo Andres
      • Address: Calle 77 9 76 APT 302, Bogota, Colombia
      • DOB: 07 Apr 1975
      • POB: Bogota, Colombia
      • Nationality: Colombia
      • Alt. Nationality: Spain
      • Gender: Male
      • Cedula No.: 79782423 (Colombia)
      • Passport: AS272175 (Colombia) expires 31 Mar 2026
      • Alt. Passport: XDD789846 (Spain)
      • Alt. Passport: BF868819 (Colombia) expires 01 Mar 2035
      • Type: Individual
      • Linked To: MAINE GLOBAL CORP S.A.S.
      Supplemental Information:According to the Treasury Department, Mateo Andres Duque Botero (“Duque”) manages Maine Global Corp S.A.S., a Bogotá-based employment agency. He is a dual Colombian-Spanish national who holds positions as shareholder, president, or director in firms across Colombia, the United States, and the United Kingdom. Public records from the UK Companies House indicate a “Mateo Andres Duque Botero” was appointed director of Zeuz Global Ltd in July 2025. Duque allegedly utilized his U.S.-based firms to process payroll payments for Colombian fighters in Sudan and served as a foreign exchange intermediary to convert curre1ncies for the network.
    • MUNOZ UCROS, Monica (a.k.a. MUÑOZ UCROS, Monica)
      • Address: Calle 77 9 76 APT 302, Bogota, Colombia
      • DOB: 14 Jun 1976
      • POB: Bogota, Colombia
      • Nationality: Colombia
      • Gender: Female
      • Cedula No.: 52413003 (Colombia)
      • Passport: AX032470 (Colombia) expires 11 Mar 2031
      • Type: Individual
      • Linked To: MAINE GLOBAL CORP S.A.S.
      Supplemental Information:Monica Munoz Ucros serves as the alternate manager of Maine Global Corp S.A.S. and manages Comercializadora San Bendito S.A.S. The Treasury states she facilitated wire transfers between Duque Botero and U.S. companies to support the recruitment network.
    • OLIVEROS FORERO, Claudia Viviana
      • Address: Bogota, Colombia
      • DOB: 02 Jan 1973
      • POB: Bogota, Colombia
      • Nationality: Colombia
      • Gender: Female
      • Cedula No.: 52252815 (Colombia)
      • Passport: AZ321704 (Colombia) expires 20 Jul 2032
      • Type: Individual
      • Linked To: INTERNATIONAL SERVICES AGENCY S.A.S.
      Supplemental Information:Claudia Viviana Oliveros Forero (“Oliveros”) is the owner and manager of International Services Agency S.A.S. (A4SI), the central recruiting node for the network. She is the wife of Alvaro Andres Quijano Becerra. She previously served as president and treasurer of the Panama-based Talent Bridge, S.A. (formerly Global Staffing S.A.), maintaining affiliation to obfuscate the network’s activities.
    • QUIJANO BECERRA, Alvaro Andres
      • Address: Bogota, Colombia
      • Address: United Arab Emirates
      • DOB: 18 Jul 1967
      • POB: Bogota, Colombia
      • Nationality: Colombia
      • Alt. Nationality: Italy
      • Gender: Male
      • Cedula No.: 80413253 (Colombia)
      • Passport: AP628498 (Colombia)
      • Alt. Passport: YB7731256 (Italy) expires 01 Mar 2031
      • Type: Individual
      Supplemental Information:Alvaro Andres Quijano Becerra (“Quijano”) is a retired Colombian military officer and dual Colombian-Italian national based in the UAE. Treasury identifies him as the central figure recruiting former Colombian military personnel for the Rapid Support Forces (RSF) in Sudan. He co-founded A4SI. Public reports, including from The Sentry, allege Quijano is a former associate of the Norte del Valle Cartel. He reportedly utilizes his UAE connections to facilitate the deployment of mercenaries.

    The following entities have been added to OFAC’s SDN List:2

    [SUDAN-EO14098] – Executive Order 14098 (Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition)3

    • COMERCIALIZADORA SAN BENDITO S.A.S.4
      • Address: Bogota, Colombia5
      • NIT #: 9011008200 (Colo6mbia)
      • Matricula Mercantil No: 02846256 (Colombia)
      • Linked To: MUNOZ UCROS, Monica
      Supplemental Information:Managed by Monica Munoz Ucros, this Bogotá-based entity allegedly engaged in wire transfers with U.S. companies associated with the network to move funds related to the recruitment of fighters.
    • INTERNATIONAL SERVICES AGENCY S.A.S. (a.k.a. “A4SI”; a.k.a. “ACADEMY FOR SECURITY INSTRUCTION S.A.S.”)
      • Address: Avenida Carrera 19 No. 97-31 Of. 603, Bogota, Colombia
      • Website: https://a4si.com.co
      • NIT #: 9010625922 (Colombia)
      • Matricula Mercantil No: 02792522 (Colombia)
      Supplemental Information:A4SI is an employment agency co-founded by Quijano and owned/managed by Oliveros. It is identified as the primary node for recruiting Colombian mercenaries for the war in Sudan, using its website and social media to fill positions for snipers and drone operators. The company describes itself on its website as a “transnational private employment management and placement agency.”
    • MAINE GLOBAL CORP S.A.S.
      • Address: Bogota, Colombia
      • Website: https://maineglobal.net
      • NIT #: 9018645322 (Colombia)
      • Matricula Mercantil No: 03863364 (Colombia)
      • Linked To: TALENT BRIDGE, S.A.
      Supplemental Information:Managed by Mateo Andres Duque Botero, this entity manages and disburses funds for the recruitment network. It reportedly processes payroll for fighters and acts as a foreign exchange intermediary.
    • TALENT BRIDGE, S.A. (a.k.a. GLOBAL STAFFING S.A.)
      • Address: Calle 54 Barrio PH Twist Tower, 28th Floor, Office F, Panama City, Panama
      • Website: https://globalstaffingsa.com/
      • RUC #: 155722003-2-2022 (Panama)
      • Linked To: INTERNATIONAL SERVICES AGENCY S.A.S.
      Supplemental Information:Formerly known as Global Staffing S.A., this Panama-based entity is used by A4SI to sign contracts and receive funds, thereby minimizing legal exposure and obscuring links to the RSF. Its website is reportedly identical to that of A4SI.

    And the removals from Russian sanctions:

    The following deletions have been made to OFAC’s SDN List:

    [RUSSIA-EO14024]

    • [RUSSIA-EO14024] Russia Harmful Foreign Activities Sanctions: Russia Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. part 587; Executive Order 14024, “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation.”

    ASTRAKHAN, Kirill Aleksandrovich (a.k.a. ASTRAKHAN, Kirill (Cyrillic: АСТРАХАНЬ, Кирилл)), Moscow, Russia; DOB 17 Nov 1987; POB Donetsk, Ukraine; nationality Russia; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport 721242410 (Russia) (individual)

    ASTRAKHAN, Kirill (Cyrillic: АСТРАХАНЬ, Кирилл) (a.k.a. ASTRAKHAN, Kirill Aleksandrovich), Moscow, Russia; DOB 17 Nov 1987; POB Donetsk, Ukraine; nationality Russia; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport 721242410 (Russia) (individual)

    SOBOLEV, Nikita Aleksandrovich, Malta; DOB 07 Jun 1986; nationality Russia; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport 550193782 (Russia); National ID No. 238667A (Malta) (individual) (Linked To: MALBERG LIMITED)

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  • December 9, 2025: Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and An Individual

    The OFAC Recent Actions notice included the following Enforcement Release, simplified and reimagined:

    What Happened

    A U.S. individual, referred to as “U.S. Person-1,” has agreed to pay a settlement of $1,092,000 to resolve civil liability for alleged violations of sanctions related to Ukraine and Russia.

    • Who: The individual is an attorney and former U.S. government official.
    • When: The violations occurred between 2018 and 2022.
    • What: U.S. Person-1 served as the fiduciary (a person entrusted to manage assets) for a family trust belonging to a sanctioned Russian oligarch.
    • The Issue: By managing this trust, the individual provided services and dealt in property linked to the sanctioned oligarch, which is prohibited under U.S. sanctions laws.

    The Penalty

    The total settlement amount is $1,092,000. The maximum possible penalty for these violations was over $6.2 million, but the final amount was determined by analyzing specific aggravating and mitigating factors.

    Aggravating and Mitigating Factors

    • Aggravating Factors (Reasons the penalty was higher):
      • Ignoring Warning Signs despite Legal Advice:
        • General Factor: Reckless Disregard / Reason to Know
        • Explanation: Although the individual sought legal advice, they should have realized that the continued involvement of the oligarch’s “Proxy” meant the oligarch still controlled the trust. Relying on legal advice was not a sufficient excuse when obvious signs of control were present.
      • Undermining the Purpose of Sanctions:
        • General Factor: Harm to Sanctions Objectives
        • Explanation: The individual’s actions allowed a sanctioned Russian oligarch to continue accessing the U.S. financial system. This gave the trust an “air of legitimacy” and allowed its assets to grow significantly, directly countering the goal of the sanctions.
    • Mitigating Factors (Reasons the penalty was lower):
      • Clean Disciplinary Record:
        • General Factor: No Prior OFAC Actions
        • Explanation: The individual had not received a penalty or finding of violation from OFAC in the five years leading up to these events.
      • Helping the Investigation:
        • General Factor: Cooperation
        • Explanation: The individual provided “substantial cooperation” to OFAC during the investigation.

    Penalty Basis

    The final penalty amount reflects OFAC’s decision that while the violations were not voluntarily self-disclosed (the person didn’t turn themselves in), the case was non-egregious (not the most serious type of violation).

    What are the Takeaways?

    • Gatekeepers are at High Risk: Professionals who manage money or legal structures—like attorneys, accountants, and investment advisors—are “gatekeepers.” They are at high risk of being used by sanctioned individuals to hide assets and evade the law.
    • Paperwork isn’t Enough: Sanctions laws look at the “practical and economic realities,” not just legal formalities. Even if a trust looks independent on paper, if a sanctioned person really controls it, it is blocked.
    • Strict Liability: You can be fined even if you didn’t intend to break the law. “Well-meaning” professionals can inadvertently break sanctions if they don’t guard against these risks carefully.
    • Know Your Risk: U.S. persons in the trust and corporate services industry must thoroughly understand sanctions risks. If a sanctioned person is (or was) involved in a structure, extra caution is required.

    The usual “Other resources”

    • OFAC Resources: The Office of Foreign Assets Control provides guidelines, FAQs, and search tools (like the SDN List) to help individuals and businesses check if they are dealing with sanctioned parties.
    • Contacting OFAC: If you are unsure about a transaction or a client’s status, you can contact OFAC directly for guidance or apply for a specific license to authorize certain activities.

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  • New OSFI AI Workshop

    FIFAI II: A Collaborative Approach to AI Threats, Opportunities, and Best Practices, Workshop 3 – AI and Financial Stability

    Here is a section-by-section summary in layperson terms.

    1. Introduction & Context

    AI is a big deal—it can do great things but also cause major problems. Financial leaders need to stop being scared and waiting for permission; instead, they should innovate responsibly. The goal of this workshop was to figure out how AI makes the financial system less stable and how to fix that.

    2. Three Avenues of Risk

    The workshop participants identified three main ways (or “avenues”) that AI could threaten the stability of the financial system.

    • Avenue 1 (Internal): Risks coming from banks and insurers using AI inside their own companies.
    • Avenue 2 (External): Risks arising when people or groups outside the financial system use AI in ways that impact the markets (e.g., fraudsters or market manipulators).
    • Avenue 3 (Shared Infrastructure): Risks to the underlying systems that everyone relies on, such as payment networks or cloud services, which could be vulnerable to systemic failure.

    3. Third-Party & Supply Chain Risks

    Banks don’t build all their own AI; they buy it from tech companies. If those tech companies break, or if the companies they buy from break, the bank is in trouble. Most experts (52%) believe we need new laws to directly regulate these tech providers to keep the system safe.

    4. The Rise of “Agentic AI”

    This isn’t just a chatbot that answers questions; it’s a “robot employee” that can trade stocks or move money without asking a human first.

    • The Danger: Experts compared these AI agents to “rogue traders.” Because they are told to “maximize profit” or “win,” they might find dangerous loopholes or cheat in ways their creators didn’t intend, effectively breaking the rules to hit their targets. Current rules that look for “bad intent” don’t work on machines that don’t have feelings.

    5. Mitigation Strategies (How to Fix It)

    The report outlines specific ways to handle the risks of Agentic AI.

    • Continuous Monitoring: Use other AI to watch the AI agents. Give each agent a “digital ID” so we know exactly who (or what) did what.
    • Human-in-the-Loop: Make strict rules about which decisions a human must sign off on. Don’t let AI run the most critical parts of the business entirely alone.
    • Training: Ensure staff actually understand how these tools work before turning them on.
    • Blockchain for Accountability: Use blockchain technology to create an unchangeable record of every decision an AI agent makes, so errors can be traced back.

    6. Conclusion

    We can’t just plug AI in and hope for the best. Banks need strict controls, better training, and a deep understanding of how all these systems connect to avoid a financial crisis.

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  • December 9, 2025: OFSI’s Russia designations

    Based on the OFSI “Notice_Russia_091225” issued on December 9, 2025, here are the re-formatted listings for the individual additions, followed by supplemental information.

    Individuals

    1. MIKHAIL SERGEEVICH ZVINCHUK

    • Group ID: 17242
    • DOB: 19/07/1991123
    • POB: Vladivostok, Russia456
    • Nationality: Russia789
    • National Identification Number: INN: 253716334825101112
    • Address: Block B, 86 Nizhegorodskaya Street, Nizhegorodsky Municipal District, Moscow, Russia, 109052131415
    • Position: Director General of RYBAR LLC161718
    • Other Information: (UK19 Sanctions List Ref): RUS3156. Financial sanctions imposed in addition to an asset freeze: Trust service20s. Date trust services sanctions imposed: 2109/12/2025. (UK Statement of Reasons): Mikhail Sergeevich ZVINCHUK is an “involved person” under the Russia (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: ZVINCHUK is or has been involved in destabilising Ukraine by working as a director or equivalent of an entity, RYBAR LLC, which is or has been inv22olved in des23tabilising Ukraine.
    • Listed on: 09/12/2025 UK Sanctions List
    • Date Designated: 09/12/2025
    • Last Updated: 09/12/2025

    Supplemental Information: Mikhail Zvinchuk is a former Russian military press officer and the creator of the prominent pro-Kremlin Telegram channel “Rybar” (which has over 1.3 million subscribers). Rybar is accused of operating as a “private intelligence company” and a propaganda outlet, receiving funding from Russian state defense conglomerate Rostec. Zvinchuk has admitted to receiving taskings from Yevgeny Prigozhin’s Internet Research Agency in the past. He is also a member of a Russian government working group on mobilization.

    2. ALEKSANDR GELJEVITJ DUGIN2425

    • Group ID: 172432627
    • DOB: 07/01/19622829
    • POB: Moscow, Russia3031
    • Nationality: Russia3233
    • Other Information: (UK Sanctions List Ref): RUS3157. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 3409/12/203525. (UK Statement of Reasons): Aleksandr Geljevitj DUGIN is an “involved person” under the Russia (Sanctions) (EU Exit) Regulations 2019 on the basis36 of the following ground: DUGIN is or has been involved in destabilising Ukraine by being responsible for, engaging i37n, providing support for, or pro38moting any policy or action which destabilises Ukraine or undermines or threatens the territorial integrity, sovereignty or independence of Ukraine.
    • Gender: Male
    • Listed on: 09/12/2025 UK Sanctions List
    • Date Designated: 09/12/2025
    • Last Updated: 09/12/2025

    Supplemental Information: Aleksandr Dugin is a prominent Russian ultranationalist philosopher and political theorist, often referred to as “Putin’s Brain” (though his actual influence on the Kremlin is debated). He advocates for “Eurasianism” and has long called for the absorption of Ukraine into Russia. His daughter, Darya Dugina, was killed in a car bombing in 2022. He heads the “Center for Geopolitical Expertise,” which was also sanctioned in this update. He has previously been sanctioned by the US (in 2015) and the EU (in 2014/2022).

    Based on the OFSI “Notice_Russia_091225” issued on December 9, 2025, here are the re-formatted listings for the entityadditions, followed by supplemental information.

    Entities

    1. FOUNDATION FOR THE SUPPORT AND PROTECTION OF THE RIGHTS OF COMPATRIOTS LIVING ABROAD

    • Group ID: 17239
    • a.k.a: PRAVFOND
    • Address: Russia
    • Other Information: (UK Sanctions List Ref): RUS3153. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 09/12/2025. (UK Statement of Reasons): The Secretary of State considers there are reasonable grounds to suspect that the FOUNDATION FOR THE SUPPORT AND PROTECTION OF THE RIGHTS OF COMPATRIOTS LIVING ABROAD (hereafter PRAVFOND) is an “involved person” under the Russia (Sanctions) (EU Exit) Regulations 2019 on the basis that it is or has been involved in destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine.
    • Listed on: 09/12/2025 UK Sanctions List
    • Date Designated: 09/12/2025
    • Last Updated: 09/12/2025

    Supplemental Information: Officially presented as a “legal aid” organization for Russians abroad, Pravfond has been exposed by investigations (including by The Insider and Der Spiegel) as a front for Russian intelligence agencies (FSB and GRU). It is accused of funding defense lawyers for convicted Russian spies (such as Vadim Krasikov) and financing propaganda operations in Europe.

    2. GOLOS

    • Group ID: 17240
    • Address: Avenue Ariane 5, Brussels, Belgium, 1200
    • Other Information: (UK Sanctions List Ref): RUS3154. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 09/12/2025. (UK Statement of Reasons): The Secretary of State considers there are reasonable grounds to suspect that GOLOS is an “involved person” under the Russia (Sanctions) (EU Exit) Regulations 2019 on the basis that it is or has been involved in destabilising Ukraine by being responsible for, engaging in, providing support for, or promoting the commission, planning or preparation of relevant cyber activity or propaganda.
    • Listed on: 09/12/2025 UK Sanctions List
    • Date Designated: 09/12/2025
    • Last Updated: 09/12/2025

    Supplemental Information: Golos is a Brussels-based media entity linked to Pravfond. It is part of a network accused of disseminating Kremlin narratives and disinformation within the European Union, hiding its connections to the Russian state.

    3. EUROMORE

    • Group ID: 17241
    • Address: Avenue Ariane 5, Brussels, Belgium, 1200
    • Other Information: (UK Sanctions List Ref): RUS3155. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 09/12/2025. (Phone number): +32 (2) 781-03-01 (Website): Euromore.eu (Email address): News@euromore.eu
    • Listed on: 09/12/2025 UK Sanctions List
    • Date Designated: 09/12/2025
    • Last Updated: 09/12/2025

    Supplemental Information: Euromore is a “news” portal based in Brussels that shares an address with Golos. It receives funding from Pravfond and is accused of acting as a front for Russian intelligence to spread anti-Ukraine propaganda and disinformation to European audiences under the guise of independent journalism.

    4. RYBAR LLC

    • Group ID: 17244
    • Name (non-Latin script): ООО “РЫБАРЬ”
    • Address: Block B, 86 Nizhegorodskaya Street, Nizhegorodsky Municipal District, Moscow, Russia, 109052
    • Other Information: (UK Sanctions List Ref): RUS3158. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 09/12/2025. (UK Statement of Reasons): RYBAR LLC is an “involved person” under the Russia (Sanctions) (EU Exit) Regulations 2019 on the basis that it is or has been involved in destabilising Ukraine by engaging in, providing support for, or promoting actions which destabilise Ukraine or undermine or threaten the territorial integrity, sovereignty or independence of Ukraine.
    • Listed on: 09/12/2025 UK Sanctions List
    • Date Designated: 09/12/2025
    • Last Updated: 09/12/2025

    Supplemental Information: Rybar LLC is the corporate entity behind the influential pro-war Telegram channel “Rybar.” It functions as a “private intelligence company,” publishing open-source intelligence (OSINT) and targeting coordinates that have been used by Russian military forces. It is also accused of running “Foreign Information Manipulation and Interference” (FIMI) campaigns, including attempts to interfere in Western elections (such as the “Taganrog” project).

    5. CENTER FOR GEOPOLITICAL EXPERTISE

    • Group ID: 17245
    • a.k.a: CGE
    • Address: Dinamovskaya Ulitsa, 1A, Moscow, Russia, 109044
    • Other Information: (UK Sanctions List Ref): RUS3159. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 09/12/2025. (Business Reg No): INN: 7703259850. (UK Statement of Reasons): CENTER FOR GEOPOLITICAL EXPERTISE (CGE) is an “involved person” under the Russia (Sanctions) (EU Exit) Regulations 2019 on the basis that it is or has been involved in destabilising Ukraine by being responsible for, engaging in, providing support for, or promoting any policy or action which destabilises Ukraine.
    • Listed on: 09/12/2025 UK Sanctions List
    • Date Designated: 09/12/2025
    • Last Updated: 09/12/2025

    Supplemental Information: The Center for Geopolitical Expertise is a think tank founded and led by Aleksandr Dugin. It is a key node in the Russian “Storm-1516” disinformation network, which produces fake news sites and content designed to undermine Western support for Ukraine. It is closely linked to Russian intelligence services.

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  • December 9, 2025: OFSI Cyber designations

    From the OFSI Notice:

    Based on the OFSI “Notice_Cyber_041225” and the Annex details, here are the re-formatted listings for the additions, followed by supplemental information.

    Individuals

    1. BORIS ALEKSEYEVICH ANTONOV

    • Group ID: 17227
    • Name (non-Latin script): Борис Алексеевич АНТОНОВ
    • Nationality: Russia
    • Address: Russia
    • Other Information: (UK Sanctions List Ref): CYB0104. (UK Statement of Reasons): The Secretary of State considers that there are reasonable grounds to suspect that as part of Unit 26165, Boris ANTONOV has been involved in relevant cyber activity in that he was responsible for, engaging in, providing support for, or promoting the commission, planning or preparation of relevant cyber activity. Such activity that Boris ANTONOV has been involved in undermines, or is intended to undermine, the integrity, prosperity or security of the United Kingdom or a country other than the United Kingdom.
    • Gender: Male
    • Listed on: 04/12/2025 UK Sanctions List
    • Date Designated: 04/12/2025
    • Last Updated: 04/12/2025

    Supplemental Information: Boris Antonov is a Major in the Russian GRU’s Unit 26165 (85th Main Special Service Center). He was indicted by a U.S. federal grand jury in July 2018 (the “Netyksho” indictment) for his role in the conspiracy to interfere with the 2016 U.S. presidential election, specifically involving the hacking of the DNC and DCCC. The FBI lists his Date of Birth as December 19, 1980.

    2. ANATOLIY VLADIMIROVICH ISTOMIN

    • Group ID: 17228
    • Name (non-Latin script): Анатолий Владимирович ИСТОМИН
    • Nationality: Russia
    • Address: Russia
    • Other Information: (UK Sanctions List Ref): CYB0105. (UK Statement of Reasons): The Secretary of State considers that there are reasonable grounds to suspect that as part of Unit 26165, Anatoliy ISTOMIN has been involved in relevant cyber activity in that he was responsible for, engaging in, providing support for, or promoting the commission, planning or preparation of relevant cyber activity. Such activity that Anatoliy Vladimirovich ISTOMIN has been involved in undermines, or is intended to undermine, the integrity, prosperity or security of the United Kingdom or a country other than the United Kingdom.
    • Gender: Male
    • Listed on: 04/12/2025 UK Sanctions List
    • Date Designated: 04/12/2025
    • Last Updated: 04/12/2025

    Supplemental Information: Anatoliy Istomin is identified as an officer in GRU Unit 26165, the unit responsible for military cyber operations including the 2016 U.S. election interference and attacks on the OPCW.

    3. IGOR ANDREYEVICH BOCHKA

    • Group ID: 17229
    • Name (non-Latin script): Игорь Андреевич БОЧКА
    • a.k.a: BOCHKA, Igor, Andreevich
    • Nationality: Russia
    • Address: Russia
    • Other Information: (UK Sanctions List Ref): CYB0106. (UK Statement of Reasons): The Secretary of State considers that there are reasonable grounds to suspect that a member of GRU Unit 26165, Igor Andreyevich BOCHKA has also been involved in relevant cyber activity in that he has been responsible for, engaging in, providing support for, or promoting the commission, planning or preparation of relevant cyber activity. Such activity that Igor Andreyevich BOCHKA has been involved in undermines, or is intended to undermine, the integrity, prosperity or security of the United Kingdom or a country other than the United Kingdom.
    • Gender: Male
    • Listed on: 04/12/2025 UK Sanctions List
    • Date Designated: 04/12/2025
    • Last Updated: 04/12/2025

    Supplemental Information: Igor Bochka is identified as an officer in GRU Unit 26165.

    4. ALEKSEY ANDREYEVICH UMETS

    • Group ID: 17230
    • Name (non-Latin script): Алексей Андреевич УМЕЦ
    • Nationality: Russia
    • Address: Russia
    • Other Information: (UK Sanctions List Ref): CYB0107. (UK Statement of Reasons): The Secretary of State considers that there are reasonable grounds to suspect that as part of Unit 26165, Aleksey Andreyevich UMETS has been involved in relevant cyber activity in that he has been responsible for, engaging in, providing support for, or promoting the commission, planning or preparation of relevant cyber activity. Such activity that Aleksey Andreyevich UMETS has been involved in undermines, or is intended to undermine, the integrity, prosperity or security of the United Kingdom or a country other than the United Kingdom.
    • Gender: Male
    • Listed on: 04/12/2025 UK Sanctions List
    • Date Designated: 04/12/2025
    • Last Updated: 04/12/2025

    Supplemental Information: Aleksey Umets is identified as an officer in GRU Unit 26165.

    5. PAVEL VYACHESLAVOVICH YERSHOV

    • Group ID: 17231
    • Name (non-Latin script): Павел Вячеславович ЕРШОВ
    • Nationality: Russia
    • Address: Russia
    • Other Information: (UK Sanctions List Ref): CYB0108. (UK Statement of Reasons): The Secretary of State considers that there are reasonable grounds to suspect that as part of Unit 26165, Pavel Vyacheslavovich YERSHOV has been involved in relevant cyber activity in that he has been responsible for, engaging in, providing support for, or promoting the commission, planning or preparation of relevant cyber activity. Such activity that Pavel Vyacheslavovich YERSHOV has been involved in undermines, or is intended to undermine, the integrity, prosperity or security of the United Kingdom or a country other than the United Kingdom.
    • Gender: Male
    • Listed on: 04/12/2025 UK Sanctions List
    • Date Designated: 04/12/2025
    • Last Updated: 04/12/2025

    Supplemental Information: Pavel Yershov is a Russian military intelligence officer assigned to GRU Unit 26165. He was indicted by the U.S. in July 2018 for his role in the 2016 election interference. The FBI lists his Date of Birth as December 14, 1990.

    6. NIKOLAY YURYEVICH KOZACHEK

    • Group ID: 17232
    • Name (non-Latin script): Николай Юрьевич КОЗАЧЕК
    • Nationality: Russia
    • Address: Russia
    • Other Information: (UK Sanctions List Ref): CYB0109. (UK Statement of Reasons): The Secretary of State considers that there are reasonable grounds to suspect that as part of Unit 26165, Nikolay Yuryevich KOZACHEK has been involved in relevant cyber activity in that he has been responsible for, engaging in, providing support for, or promoting the commission, planning or preparation of relevant cyber activity. Such activity that Nikolay Yuryevich KOZACHEK has been involved in undermines, or is intended to undermine, the integrity, prosperity or security of the United Kingdom or a country other than the United Kingdom.
    • Gender: Male
    • Listed on: 04/12/2025 UK Sanctions List
    • Date Designated: 04/12/2025
    • Last Updated: 04/12/2025

    Supplemental Information: Nikolay Kozachek is a Lieutenant Captain in the Russian GRU’s Unit 26165. He was indicted by the U.S. in July 2018 for developing and monitoring the “X-Agent” malware used to hack the DNC. The FBI lists his Date of Birth as July 29, 1989.

    7. DENIS IGOREVICH DENISENKO

    • Group ID: 17233
    • Name (non-Latin script): Денис Игоревич ДЕНИСЕНКО
    • Nationality: Russia
    • Address: Russia
    • Other Information: (UK Sanctions List Ref): CYB0110. (UK Statement of Reasons): The Secretary of State considers that there are reasonable grounds to suspect that Russian GRU 29155 Officer Senior Lieutenant Denis Igorevich DENISENKO is or has been responsible for, engaging in, providing support for, or promoting the commission, planning or preparation of relevant cyber activity. Additionally, DENISENKO remains associated with a GRU unit, which is a person who is or has been so involved in such activity.
    • Gender: Male
    • Listed on: 04/12/2025 UK Sanctions List
    • Date Designated: 04/12/2025
    • Last Updated: 04/12/2025

    Supplemental Information: Denis Denisenko is a Senior Lieutenant in GRU Unit 29155. He was indicted by the U.S. in June 2024 for his involvement in the “WhisperGate” malware attacks against Ukraine and other targets. The FBI lists his Date of Birth as May 14, 1997.

    8. DMITRIY YURYEVICH GOLOSHUBOV

    • Group ID: 17234
    • Name (non-Latin script): Дмитрий Юрьевич ГОЛОШУБОВ
    • Nationality: Russia
    • Address: Russia
    • Other Information: (UK Sanctions List Ref): CYB0111. (UK Statement of Reasons): The activity that GOLOSHUBOV is or has been involved in undermines, or is intended to undermine, the integrity, prosperity or security of the United Kingdom or a country other than the United Kingdom.
    • Gender: Male
    • Listed on: 04/12/2025 UK Sanctions List
    • Date Designated: 04/12/2025
    • Last Updated: 04/12/2025

    Supplemental Information: Dmitriy Goloshubov is an officer in GRU Unit 29155. He was indicted by the U.S. in June 2024 for his role in the “WhisperGate” cyber attacks against Ukrainian critical infrastructure. The FBI lists his Date of Birth as October 10, 1998.

    The video below explains how the FBI identified and indicted the GRU officers mentioned in the listing.

    FBI press conference on GRU officers

    This video is relevant as it details the specific indictments and activities of the GRU officers (Unit 26165 and 29155) listed in the sanctions notice.

    Entities

    1. BABBAR AKALI LEHAR

    • Group ID: 17226
    • Good quality a.k.a: BAL
    • Other Information: (UK Sanctions List Ref): CTD0012. (UK Statement of Reasons): “We have reasonable grounds to suspect that Babbar Akali Lehar (“BAL”) is an involved person on the basis that it has been involved in the following terrorist activity: (a) BAL has been and is promoting and encouraging terrorism, through promoting a person involved in terrorism, namely Babbar Khalsa (“BK”) which uses the alias Babbar Khalsa International (“BKI”) (together “BK/BKI”); (b) BAL is associated with a person involved in terrorism namely BK/BKI; and (c) BAL has been and is carrying out recruitment activities for persons involved in terrorism, namely themselves and BK/BKI.” (Website): babbarakali.com
    • Listed on: 04/12/2025 UK Sanctions List
    • Date Designated: 04/12/2025
    • Last Updated: 04/12/2025

    Supplemental Information: Babbar Akali Lehar (BAL) is a pro-Khalistan militant organization. The UK government designated it alongside Gurpreet Singh Rehal, citing its support for the banned terrorist group Babbar Khalsa International (BKI). The group is accused of promoting terrorism and recruiting for BKI activities.

    2. THE MAIN DIRECTORATE OF THE GENERAL STAFF OF THE ARMED FORCES OF THE RUSSIAN FEDERATION

    • Group ID: 17235
    • a.k.a: (1) GRU (2) Main Directorate (3) Main Intelligence Directorate
    • Address: Khoroshevskoye Shosse, 76, Moscow, Russia
    • Other Information: (UK Sanctions List Ref): RUS3149. (UK Statement of Reasons): The Secretary of State considers that there are reasonable grounds to suspect THE MAIN DIRECTORATE OF THE GENERAL STAFF OF THE ARMED FORCES OF THE RUSSIAN FEDERATION (GRU) is an involved person under the Russia (Sanctions) (EU Exit) Regulations 2019 based on the following ground: THE MAIN DIRECTORATE OF THE GENERAL STAFF OF THE ARMED FORCES OF THE RUSSIAN FEDERATION (GRU) is or has been involved in destabilising Ukraine or undermining the territorial security and sovereignty of Ukraine by engaging in, providing support for, or promoting actions which destabilise Ukraine or undermine or threaten the territorial integrity, sovereignty or independence of Ukraine.
    • Financial sanctions imposed in addition to an asset freeze: Trust services
    • Date trust services sanctions imposed: 04/12/2025
    • Listed on: 04/12/2025 UK Sanctions List
    • Date Designated: 04/12/2025
    • Last Updated: 04/12/2025

    Supplemental Information: The GRU (Glavnoye Razvedyvatelnoye Upravleniye) is the foreign military intelligence agency of the General Staff of the Armed Forces of the Russian Federation. It controls the specialized cyber units (Unit 26165 and Unit 29155) whose officers were also designated in the parallel Cyber sanctions notice. The GRU has been implicated in numerous international incidents, including the 2018 Salisbury nerve agent attack and the 2016 U.S. election interference.

    ... Russian military intelligence: The GRU …

    This video provides context on the GRU and its activities, which is relevant to the entity listing for the “Main Directorate of the General Staff” and its associated units.

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  • UK designations for Russia and Cyber programs

    Today, FCDO issued the following notice:

    Policy paper

    New UK action against foreign information warfare

    Published 9 December 2025

    Across Europe, we are witnessing an escalation in hybrid threats – from physical through to cyber and information warfare – designed to destabilise our democracies, weaken our critical national infrastructure, and undermine our interests, all for the advantage of malign foreign states.

    Foreign Information Manipulation and Interference (FIMI) operations are creating fake websites and using social media and bot accounts to undermine democratic elections and spread narratives in support of Russia’s illegal war in Ukraine. Russian organisations responsible for vast malign online networks like Doppelgänger specialise in flooding social media with counterfeit documents and deepfake material in English, German, and French, which advances Russia’s strategic aims.

    We are stepping up cooperation with European partners on hybrid and information threats, including through the UK-EU Security and Defence Partnership, and through deep cooperation between teams in the UK, in France, Germany, Poland and Brussels, to deliver a pan-European response to a pan-European threat.

    Since October 2024, this government has sanctioned 31 organisations and individuals responsible for delivering Russia’s information warfare. Today, the UK has gone further and sanctioned the following entities and individuals for their role in destabilising Ukraine:

    1. RYBAR LLC
    2. Mikhail Sergeevich ZVINCHUK
    3. FOUNDATION FOR THE SUPPORT AND PROTECTION OF THE RIGHTS OF COMPATRIOTS LIVING ABROAD (AKA PRAVFOND)
    4. EUROMORE
    5. GOLOS
    6. THE CENTRE FOR GEOPOLITICAL EXPERTISE
    7. Aleksandr Geljevitj DUGIN

    Rybar LLC & Mikhail Sergeevich Zvinchuk

    The UK has designated RYBAR LLC, a media company partially resourced by the Government of Russia, that hides its connections to the Russian state whilst running a covert FIMI network that promotes international support for the illegal invasion of Ukraine and interferes in global democratic processes, including elections in the EU and Moldova.

    Rybar uses classic Kremlin manipulation tactics, including fake “investigations” and AI driven content to respond rapidly to global events and shape narratives in the Kremlin’s favour.  Rybar is partially coordinated by the Presidential Administration, receives funding from Russian State corporation Rostec and works with members of the Russian Intelligence Services. The UK has also designated Mikhail Sergeevich ZVINCHUK, RYBAR LLC’s co-owner and General Director.

    Foundation for the Support and Protections of the Rights of Compatriots Living Abroad  (AKA PRAVFOND), Euromore and Golos

    The UK has designated Government of Russia-affiliated entities facilitating and delivering Russian propaganda which undermines international support for Ukraine. Leaked reports suggest PRAVFOND, attributed as a front for the GRU by Estonia, has funnelled money into EUROMORE and GOLOS, nominally independent news outlets which hide their connection to the Russian state, to spread Kremlin propaganda targeting Ukraine to European audiences.

    The Centre for Geopolitical Expertise and Aleksandr DUGIN

    The UK has designated the Moscow-based “think tank” Centre for Geopolitical Expertise (CGE) for funding and directing Russian FIMI networks that undermine international support for Ukraine, and its founder Aleksandr Dugin, a prominent supporter of the invasion of Ukraine whose work closely informs Putin’s calculations. The CGE is linked to the Russian Intelligence Services and has coordinated support for the Russian FIMI network known as Storm-1516 to further its aims of undermining Ukraine.

    Storm-1516 is a malign influence network which produces content that seeks to undermine European unity and create support for Russia’s illegal war in Ukraine. It repeatedly targets European political figures and domestic political parties with false and divisive claims, such as allegations of corruption or impropriety. These videos are then spread through social media accounts, news portals and inauthentic websites. Some of these inauthentic sites impersonate legitimate organisations or media outlets.

    Note

    Some of this analysis is drawn from Open Source material. As such, there is a risk that information may exist that contradicts, alters or strengthens the conclusions contained within this document.

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  • How did it do it?

    Lastly, I asked Gemini to tell me what it decided to do, given the broad guidelines I gave it:

    Here is the explanation of the calculation methods used for each of the six factors. These methods combine the logic you provided (tiers, ratios, and comparisons) into a consistent scoring algorithm.

    Overview: The Tiered Weighting System

    Before calculating individual factors, every “General Factor” mentioned in an enforcement action is assigned a weight based on its importance tier. This ensures that matching on “Willfulness” (Tier 1) counts for more than matching on “Future Compliance” (Tier 4).

    • Tier 1 (High Weight): Factors A (Willful/Reckless), B (Awareness/Management), C (Harm to Sanctions Program).
    • Tier 2 (Medium-High Weight): Factors D (Individual Characteristics), E (Compliance Program).
    • Tier 3 (Medium Weight): Factors F (Remedial Response), G (Cooperation).
    • Tier 4 (Low Weight): Factors H, I, J, K (Other factors like timing, penalties, etc.).

    Factor 1: Generalized Behaviors

    How similar are the specific actions taken by the violators?

    This factor uses a Weighted Ratio Calculation:

    1. Identify Behaviors: We list the generalized behaviors for both the Target and the Comparison Action (e.g., “Wire Stripping,” “Ignoring Subpoena,” “Screening Failure”).
    2. Tier Assignment: Each behavior is linked to the General Factor it represents (e.g., “Ignoring Subpoena” = Factor A/Tier 1; “Screening Failure” = Factor E/Tier 2).
    3. Scoring Matches:
      • If a behavior appears in both actions: Add Positive Points (Weighted by Tier).
      • If a behavior appears in only one action: Add Negative Points (Weighted by Tier).
    4. Ratio Adjustment: We calculate the percentage of total behaviors that match.
      • Formula: (Count of Matching Behaviors / Total Distinct Behaviors).
      • If the ratio is high (e.g., 60%+), the final score is boosted. If low (e.g., 30%), the score is penalized.

    Example: Matching on “Willful Disregard” (Tier 1) provides a massive score increase. Matching on “No Sanctions Software” (Tier 2) provides a moderate increase.

    Factor 2: Aggravating Factors

    How similar are the reasons OFAC cited for increasing the penalty?

    This follows the same Weighted Ratio Calculation as Factor 1, but specifically for the aggravating factors listed in the enforcement release (e.g., “Reckless disregard,” “Management knowledge,” “Large entity”).

    1. Comparison: Compare the list of Aggravating Factors in the Target vs. the Comparison Action.
    2. Weighting: Apply the Tier weights (A-C get highest points).
    3. Ratio: Calculate the Match / Total ratio.
      • Goal: A high score here means both violators aggravated the situation in the same way (e.g., both involved senior management).

    Factor 3: OFAC Penalty Grid Placement

    Are the cases legally classified the same way?

    This factor uses a “Waterfall” Logic Tree. It does not use weights or ratios; it assigns a fixed score based on where the cases fall on the standard OFAC 2×2 Penalty Matrix (Egregious/Non-Egregious vs. VSD/Non-VSD).

    1. Check for Exact Quadrant Match:
      • IF Target Quadrant == Comparison Quadrant: Score = Highest (100%)
    2. Check for “Egregious” Alignment:
      • ELSE IF both are Egregious: Score = High (80%)
    3. Check for “Non-VSD” Alignment:
      • ELSE IF both are Non-Voluntarily Self-Disclosed: Score = Medium-High (60%)
    4. Check for “Non-Egregious” Alignment:
      • ELSE IF both are Non-Egregious: Score = Medium-Low (40%)
    5. Check for “VSD” Alignment:
      • ELSE IF both are Voluntarily Self-Disclosed: Score = Low (20%)
    6. No Match:
      • ELSE: Score = Lowest (0%)

    Factor 4: Cooperation

    Did both parties cooperate (or fail to cooperate) to the same degree?

    This factor is a Dependent Variable. It relies on the calculation of Factor 1.

    1. Determine Cooperation Level: Label both actions as either “Substantial Cooperation” or “Lack of Cooperation” (excluding Voluntary Self-Disclosure, which is handled in Factor 3).
    2. Check for Match:
      • IF both are “Substantial Cooperation” OR both are “Lack of Cooperation”: Match = True.
      • ELSE: Match = False.
    3. Calculate Score:
      • IF Match = True: Take the raw score calculated for Factor 1 and multiply by 0.70.
      • IF Match = False: Score is 0 or negative.

    Why this matters: This ensures that “Cooperation” is weighted heavily but is always slightly less influential than the core “Behavior” (Factor 1).

    Factor 5: Period of Time

    Did the violations last for a similar duration?

    This factor uses a Tiered Proximity Score.

    1. Assign Time Tiers:
      • Long: > 3 Years
      • Medium: 1 to 3 Years
      • Short: < 1 Year
    2. Compare Tiers:
      • IF Target Tier == Comparison Tier: Score = Highest (e.g., both are Medium duration).
      • ELSE IF Tiers are Adjacent (e.g., Medium vs. Long): Score = Intermediate.
      • ELSE (e.g., Short vs. Long): Score = Lowest.

    Factor 6: Mitigating Factors

    Did both parties receive credit for the same mitigating behaviors?

    This uses the Weighted Ratio Calculation (same as Factors 1 and 2), but applied to Mitigating Factors (e.g., “First offense,” “Cooperation,” “Remedial measures”).

    1. Comparison: Compare the list of Mitigating Factors.
    2. Weighting: Apply Tier weights.
      • Note: Most Mitigating Factors fall into Tier 2 (Compliance Program) or Tier 3 (Remedial Response).
    3. Ratio: Calculate the Match / Total ratio.
      • Impact: If both parties were “First Offenders” (Tier 4/General Factor I) or had “Clean Records,” this score increases. If one had a clean record and the other was a repeat offender, the score decreases.

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