Mr. Sanctions

Category: OFAC (US)

  • April 3, 2026: OFAC removes 2 listings (1 person) from Russian sanctions

    Russia-related Designation Removal

    Delistings:

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

    OFAC Program: RUSSIA-EO14024 Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR Part 587; Executive Order 14024.

    ZADORNOV, Mikhail Mikhaylovich (Cyrillic: ЗАДОРНОВ, Михаил Михайлович) (a.k.a. ZADORNOV, Mikhail Mikhailovich), Str. Malaya Molchanovka, 8-29, Moscow 121069, Russia; DOB 04 May 1963; POB Moscow, Russia; nationality Russia; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport760019543 (Russia) (individual) (Linked To: PUBLIC JOINT STOCK COMPANY BANK FINANCIAL CORPORATION OTKRITIE).

    ZADORNOV, Mikhail Mikhailovich (a.k.a. ZADORNOV, Mikhail Mikhaylovich (Cyrillic: ЗАДОРНОВ, Михаил Михайлович)), Str. Malaya Molchanovka, 8-29, Moscow 121069, Russia; DOB 04 May 1963; POB Moscow, Russia; nationality Russia; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport760019543 (Russia) (individual) (Linked To: PUBLIC JOINT STOCK COMPANY BANK FINANCIAL CORPORATION OTKRITIE).

    By the way, to unlock the full functionality of all Apps, enable Gemini Apps Activity.

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  • April 1, 2026: Not a joke – Delcy Rodriguez delisted by OFAC

    Venezuela-related Designation Removal

    Delistings:

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

    OFAC Program: VENEZUELA Executive Order 13692 of March 8, 2015, “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela,” and/or Executive Order 13884 of August 5, 2019, “Blocking Property of the Government of Venezuela.”

    RODRIGUEZ GOMEZ, Delcy Eloina (**AKA: ** RODRIGUEZ, Delcy), Capital District, Venezuela; **DOB: ** 18 May 1969; **citizen: ** Venezuela; **Gender: ** Female; **Cedula No.: ** 10353667 (Venezuela) (individual)

    RODRIGUEZ, Delcy (**AKA: ** RODRIGUEZ GOMEZ, Delcy Eloina), Capital District, Venezuela; **DOB: ** 18 May 1969; **citizen: ** Venezuela; **Gender: ** Female; **Cedula No.: ** 10353667 (Venezuela) (individual)

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  • April 1, 2026: OFAC issues more aggressive guidance, a General License and FAQs about the Shadow Fleet

    U.S. DEPARTMENT OF THE TREASURY

    Office of Foreign Assets Control

    April 1, 2026

    Publication of Sanctions Advisory: Guidance on Identifying “Non-Standard Maritime Silhouettes” and Active Camouflage within the Shadow Fleet

    The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), in coordination with the U.S. Department of State and the U.S. Coast Guard, is issuing this advisory to alert the maritime industry to “Visual Signal Obfuscation” (VSO) tactics currently employed by the Shadow Fleet to circumvent the G7+ Price Cap and avoid detection in high-traffic corridors.

    As outlined in Executive Order 14501, “Addressing Extra-Territorial Maritime Deception,” U.S. persons are advised that the use of “Trompe-l’œil” hull painting, inflatable superstructure extensions, and “active-chameleon” heat-shielding technology constitutes a significant evasion risk.

    Regulatory Concerns: The “Iceberg” and “Megayacht” Protocols

    OFAC has identified a trend where sanctioned crude oil tankers are undergoing structural modifications to appear as non-sanctioned vessel types when viewed from satellite or aerial surveillance. Recent findings include:

    • Pseudo-Leisure Conversions: Tankers utilizing magnetic “hull-wraps” to mimic the visual signature of luxury pleasure craft or research vessels.
    • Active Camouflage (AC): The application of light-refractive coatings that cause the vessel to blend into sea-state patterns or, in Arctic routes, mimic the geometric profile of large icebergs.
    • Bio-Mimicry Signatures: The deployment of acoustic decoys that broadcast the frequency of migratory whale pods to confuse sonar-based tracking systems.

    Compliance Expectations

    Marine insurers, port authorities, and bunkering services are expected to conduct “Optical Due Diligence.” If a vessel’s length-to-beam ratio appears to “shimmer” or fluctuate during daylight hours, it must be flagged as a “Potential Visual Evasion Event” (PVEE).

    And a new General License:

    GL 1-APRDownload

    And a new Frequently Asked Question:

    Frequently Asked Question (FAQ) 1401

    Q: My satellite imagery shows a tanker that looks like a giant floating rubber duck. Is this a sanctioned vessel?

    A: Possibly. Under the “Strict Liability” standard, the internal cargo (crude oil) determines the sanctions status, regardless of whether the external hull is yellow, buoyant, or has a beak. OFAC recommends that you do not “squeeze” the duck until you have verified the Ultimate Beneficial Owner (UBO) via the hotline at 1-800-APR-FOOL.

    oh, and one more thing, in case it wasn’t clear…

    Thanks a bunch, Gemini! April Fool!

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  • Burning Question: The march of time (and minimizing sanctions evasion)

    so, I asked Gemini to build the story of sanctions evasion-related advisory and guidance documents. Its response:

    The latest advisory from March 31, 2026, titled “Guidance on Sham Transactions and Sanctions Evasion,” signals a new frontier in the U.S. government’s efforts to stop illicit actors from hiding their wealth. By reviewing this document and the history of OFAC’s guidance, we can see a clear evolution: sanctions have moved from simple “do not trade with this person” lists to complex “detective manuals” that require companies to spot sophisticated lies.

    Part 1: Summary of Today’s Advisory (March 31, 2026)

    Verified Document: Guidance on Sham Transactions and Sanctions Evasion.

    The core message of this document is that a “paper trail” is no longer enough to prove a transaction is legal. OFAC is warning that blocked individuals—such as sanctioned Russian oligarchs or international drug kingpins—are using “Sham Transactions” to pretend they no longer own their luxury assets (like private jets, yachts, or companies).

    Key “Red Flags” for Sham Transactions:

    • Family Transfers: A sanctioned person “sells” or transfers an asset to a spouse, child, or close associate shortly before or after being sanctioned.
    • Below-Market Deals: Selling a multi-million dollar asset for a tiny fraction of its value, or on terms that don’t make business sense.
    • Invisible Control: The sanctioned person “sells” their private jet but continues to use it for personal travel, meaning they still effectively own it.
    • Unnecessary Complexity: Using layers of shell companies in “tax haven” countries to hide who really benefits from the property.

    Part 2: The Evolution of Sanctions Evasion Guidance

    Over the last decade, OFAC’s guidance has evolved through four distinct “generations.”

    1. The “Who” Era (Foundational / Pre-2019)

    In this era, compliance was relatively simple: don’t do business with anyone on the SDN List (Specially Designated Nationals).

    • The Big Rule (2014): OFAC clarified the “50 Percent Rule,” stating that if a sanctioned person owns 50% or more of any company, that company is also automatically sanctioned—even if its name isn’t on a list.
    • The Evasion: People began splitting ownership into 49% chunks to stay “under the radar.”

    2. The “How” Era (2019: The Framework)

    OFAC realized that companies needed a “playbook” to avoid making mistakes.

    • Key Document: A Framework for OFAC Compliance Commitments (May 2019).
    • Evolution: This established the “5 Pillars” of a good compliance program: management support, risk assessment, internal controls, testing, and training. It told companies: “We won’t just look at who you trade with; we will look at how hard you tried to follow the rules”.

    3. The “Behavioral” Era (2020: Global Maritime Advisory)

    Sanctions evasion moved to the high seas, where bad actors began using “Deceptive Shipping Practices” (DSPs).

    • Key Document: 2020 Global Maritime Advisory.
    • Evolution: Guidance shifted from “Lists” to “Patterns”. Companies were told to watch for ships turning off their GPS (AIS), “spoofing” their location, or transferring cargo between ships in the middle of the ocean (STS transfers) to hide the cargo’s origin.

    4. The “Detective” Era (2023–2026: Shadow Fleets and Sham Deals)

    The current era is defined by the war in Ukraine and the “Russian Oil Price Cap”.

    • The “Shadow Fleet”: Guidance now focuses on “Ghost Ships”—older, poorly maintained vessels with fake insurance used to bypass oil price limits.
    • “Know Your Cargo” (2023): A landmark “Quint-Seal” note (issued by five agencies) told companies they must now verify the cargo, not just the customer.
    • The Latest Step (Today): The 2026 “Sham Transactions” advisory completes the circle. It warns that even when the person looks clean and the ship looks clean, the legal paperwork might be a lie.

    Summary for Non-Experts: How the “Rules of the Game” Changed

    Old Way (2016)New Way (2026)
    “Check the List”: If the name isn’t on the SDN list, you are probably fine.“Check the Vibe”: Even if the name is clean, you must ask: “Does this deal make sense? Why is this ship’s GPS off?”.
    “Simple Ownership”: Just check if a sanctioned person owns 51% of a business.“Ultimate Control”: Check if they secretly control it through a trust, a shell company, or their spouse.
    “Bank Responsibility”: Mostly banks and financial firms had to worry about this.“Industry Responsibility”: Insurers, ship captains, freight forwarders, and luxury goods dealers are now on the front lines.

    Today, OFAC treats every company as a “mini-detective agency.” If you ignore a red flag—like an oligarch suddenly “giving” his yacht to his wife for $1—the government can hold you responsible for “sham” activity.

    So, what do you think? The inclusion of the Framework Document seems a bit of a curveball (certainly I didn’t expect that to pop up), but it seems to follow a certain logic….

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  • March 31, 2026 Sanctions-palooza: OFAC Updates: Counter Narcotics Designations Removals; Russia-related Designations Removals

    Counter Narcotics Designations Removals; Russia-related Designations Removals

    Treasury Press Release: Treasury Removes Narcotics and Russia-Related Entries from SDN List

    Delistings:

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

    OFAC Program: SDNTK Foreign Narcotics Kingpin Sanctions Regulations, 31 CFR part 598

    RODRIGUEZ OLIVERA, Luis (a.k.a. MORFAN RODRIGUEZ, Luis Fernando; a.k.a. RODRIGUEZ MORFIN, Luis; a.k.a. RODRIGUEZ OLIVERA, Luis Fernando), Plaza Pabellion, Zapopan, Jalisco, Mexico; Colonia Providencia, Calle Quebec, Apt. 1127, Guadalajara, Jalisco, Mexico; 4179 Colonia Miravalle, Guadalajara, Jalisco, Mexico; Sendero Las Acacias 92, Guadalajara, Guadalajara, Jalisco, Mexico; Vereda Del Canario 1, Guadalajara, Jalisco, Mexico; Puerto de Hierro, Zapopan, Jalisco, Mexico; Fresno, CA, United States; DOB: 03 Apr 1972; alt. DOB: 1960; alt. DOB: 1966; POB: Tecalitlan, Jalisco, Mexico; nationality: Mexico; citizen: Mexico (individual).

    MORFAN RODRIGUEZ, Luis Fernando (a.k.a. RODRIGUEZ MORFIN, Luis; a.k.a. RODRIGUEZ OLIVERA, Luis; a.k.a. RODRIGUEZ OLIVERA, Luis Fernando), Plaza Pabellion, Zapopan, Jalisco, Mexico; Colonia Providencia, Calle Quebec, Apt. 1127, Guadalajara, Jalisco, Mexico; 4179 Colonia Miravalle, Guadalajara, Jalisco, Mexico; Sendero Las Acacias 92, Guadalajara, Jalisco, Mexico; Vereda Del Canario 1, Guadalajara, Jalisco, Mexico; Puerto de Hierro, Zapopan, Jalisco, Mexico; Fresno, CA, United States; DOB: 03 Apr 1972; alt. DOB: 1960; alt. DOB: 1966; POB: Tecalitlan, Jalisco, Mexico; nationality: Mexico; citizen: Mexico (individual).

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

    OFAC Program: RUSSIA-EO14024 Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation

    FESCO MONERON (Cyrillic: ФЕСКО МОНЕРОН) Container Ship 7,519GRT Russia flag; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Vessel Registration Identification: IMO 9277412 (vessel) (Linked To: PSB LIZING OOO).

    FESCO MAGADAN (Cyrillic: ФЕСКО МАГАДАН) Container Ship 7,519GRT Russia flag; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Vessel Registration Identification: IMO 9287699 (vessel) (Linked To: PSB LIZING OOO).

    SV NIKOLAY (Cyrillic: СВ НИКОЛАЙ) General Cargo Ship 7,519GRT Russia flag; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Vessel Registration Identification: IMO 9538359 (vessel) (Linked To: PSB LIZING OOO).

    Source List:

    • UNITED NEWS OF INDIA, “US removes 3 Russia-flagged ships from sanctions list,” March 31, 2026.
    • Interfax, “U.S. lifts sanctions on 3 Russian seagoing cargo vessels,” March 31, 2026.
    • ACAMS, “OFAC Removes 16 Entries from SDN List,” March 31, 2026.

    Note: The Treasury press release was not on the Recent Actions web page. Gemini found it on the Treasury website.

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  • March 31, 2026 Sanctions-palooza: OFAC issues guidance on “sham transactions” and sanctions evasion

    20260331_sham_transactions_advisoryDownload

    While this seems pretty basic, for those of us who have been in financial crime compliance for a while, it’s always good to publish this as a reminder for those new to the field or those caught up in the day-to-day who could use a refresher….

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  • March 31, 2026 Sanctions-palooza: OFAC publishes new Venezuela Frequently Asked Question

    FAQ 1247 was published today:

    1247. Do non-U.S. persons face sanctions risk for engaging in transactions authorized by General Licenses (GL) 46B, 51A, and 52?

    Answer

    No, provided that non-U.S. persons comply with certain conditions outlined in GLs 46B, 51A, and 52, as described below. Subject to certain conditions, GLs 46B, 51A, and 52 authorize established U.S. entities to engage in certain transactions involving Petróleos de Venezuela, S.A. (PdVSA), as well as certain transactions that are ordinarily incident and necessary to, among other activities, the exportation, sale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin oil, petrochemical products, or minerals (including gold). Generally, non-U.S. persons do not risk exposure to U.S. sanctions for engaging in transactions authorized under GLs 46B, 51A, or 52 — such as transacting with PdVSA or importing Venezuelan-origin oil, petrochemical products, or minerals, into a third country — provided that:

    • The non-U.S. entity was organized under the laws of a third country on or before January 29, 2025;
    • Any monetary payment to a blocked person, excluding payments for local taxes, permits, or fees, is made into the Foreign Government Deposit Funds, as specified in Executive Order 14373 of January 9, 2026, or any other account as instructed by the U.S. Department of the Treasury;
    • The payment terms are commercially reasonable;
    • The payment terms do not involve debt swaps, and are not denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;
    • The transaction does not involve a person located in or organized under the laws of the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled, directly or indirectly, by or in a joint venture with such persons;
    • The transaction does not involve an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China;
    • The transaction does not involve a blocked vessel; and
    • With respect to GL 51A, the transaction does not involve the processing or refining of Venezuelan-origin minerals, including gold, in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or the People’s Republic of China.

    These conditions are designed to ensure that transactions involving PdVSA or Venezuelan-origin oil, petrochemical products, and minerals occur through legitimate and authorized channels, consistent with efforts to restore prosperity, safety, and security to Venezuela. Non-U.S. persons who continue to transact with PdVSA or import Venezuelan-origin oil, petrochemical products, and minerals, including gold, without complying with the above conditions risk being designated themselves, including for providing financial, material, or technological support to blocked persons, being responsible for or complicit in a transaction involving deceptive practices or corruption and the Government of Venezuela, or operating in the gold or oil sectors of the Venezuelan economy. 
    Please note that GL 52 contains additional restrictions on engaging in certain transactions prohibited by other Venezuela-related Executive orders, such as transactions related to bonds and debt issued by PdVSA, as well as on the entry into a settlement agreement or the enforcement of any lien, judgment, or other order through execution, garnishment, or other judicial process purporting to transfer or otherwise alter or affect property or interests in property of any persons blocked pursuant to the Venezuela Sanctions Regulations.

    Please see FAQ 1226 for the definition of “Venezuelan-origin oil,” which includes petroleum products.

    Please see FAQ 1232 for what OFAC considers “commercially reasonable terms.”

    Please see FAQ 1239 for information on how to make authorized payments to the Foreign Government Deposit Funds, as specified in E.O. 14373.

    Date Released

    March 31, 2026

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  • March 30, 2026: New version of OFAC Lukoil International GmbH-related General License and 2 updated Frequently Asked Questions

    Today, OFAC issued Russia-related General License 131D (Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities):

    russia_gl131dDownload

    and updated FAQs 1224:

    1224. What negotiations does Russia-related General License 131D authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?

    Answer

    On October 22, 2025, OFAC designated Public Joint-Stock Company Oil Company Lukoil (Lukoil) to increase pressure on Russia’s energy sector and degrade Russia’s ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the impact of sanctions. To support such divestments and further cut off funding to Russia, OFAC issued Russia-related General License (GL) 131D, which authorizes negotiations and entry into contingent contracts with Lukoil for the sale of LIG or any of LIG’s majority-owned subsidiaries. Authorized activities include negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors. GL 131Dexpires on May 1, 2026.

    GL 131D does not authorize transactions to effectuate the actual sale, disposition, or transfer of any LIG entity or asset. Any contract entered into pursuant to GL 131D must expressly be made contingent upon the receipt of a separate authorization from OFAC. The goal of OFAC’s Russia sanctions is to place pressure on Moscow to end its war.

    As such, Treasury would evaluate any proposed sale of LIG based on factors that support U.S. national security and foreign policy objectives. OFAC expects that, at a minimum, the proposed transaction must: completely sever LIG’s ties with Lukoil; block any funds owed to Lukoil until sanctions are lifted by placing them in an account subject to U.S. jurisdiction; and not provide a windfall to Lukoil, such as by providing up-front value to Lukoil, including through asset or share swaps. Further, as a condition of any future license for effectuating a sale of LIG, OFAC expects that it will require persons purchasing LIG’s assets to seek OFAC review before further divestment of material LIG assets.

    OFAC may revoke GL 131D at any time, including if Lukoil and LIG do not appear to be engaging in good faith negotiations regarding the divestment of LIG or its assets.

    Date Updated: March 30, 2026

    Date Released

    November 19, 2025

    and 1225:

    1225. What activities do Russia-related General License 128B and General License 131D authorize related to Lukoil International GmbH (LIG)?

    Answer

    OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries (“LIG Entities”): GL 128B and GL 131D. The GLs are similar but have different expiration dates and terms as each serves a different purpose.

    • To mitigate the effects of Lukoil’s OFAC designation on retail consumers, OFAC issued on December 4, 2025 GL 128B to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation. GL 128B expires on April 29, 2026.
    • To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities. OFAC subsequently issued GL 131B, GL 131C, and GL 131D to extend the existing authorization until May 1, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

    GL 128B and GL 131D expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128B and GL 131D. Transactions undertaken in the ordinary course of business may involve (but are not limited to): supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments. Also, both GL 128B and GL 131D authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations.

    Both GL 128B and GL 131D also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation.

    Non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128B and GL 131D. Similarly, non-U.S. persons may rely upon GL 128B and GL 131Dregardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person’s activities are consistent with the terms of GL 128B and GL 131D, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.

    Date Updated: March 30, 2026

    Date Released

    December 4, 2025

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  • March 27, 2026: A Miner Set of OFAC GLs for Venezuela

    Earlier this evening, OFAC issued a new version of Venezuela General License (GL) 51 (Authorizing Certain Activities Involving Venezuelan-Origin Minerals, Including Gold):

    venezuela_gl51aDownload

    and new GLs 54 (Authorizing the Supply of Certain Items and Services for Minerals Operations in Venezuela):

    venezuela_gl54Download

    and 55 (Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela’s Minerals Sector):

    venezuela_gl55Download

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  • March 27, 2026: OFAC delists from Russian and GLOMAG sanctions programs

    Global Magnitsky Designations Removals; Russia-related Designations Removals

    Delistings:

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

    OFAC Program: GLOMAG Global Magnitsky Sanctions Regulations, 31 C.F.R. part 583; Executive Order 13818.

    PORTNOV, Andriy Volodymyrovych (Cyrillic: ПОРТНОВ, Андрій Володимирович) (a.k.a. PORTNOV, Andrij Volodymyrovych; a.k.a. PORTNOV, Andriy), Ukraine; DOB 27 Oct 1973; POB Luhansk, Ukraine; nationality Ukraine; Gender Male; Passport PU262444 (Ukraine); National ID No. CO168696 (Ukraine) (individual).

    PORTNOV, Andrij Volodymyrovych (a.k.a. PORTNOV, Andriy; a.k.a. PORTNOV, Andriy Volodymyrovych (Cyrillic:ПОРТНОВ, Андрій Володимирович)), Ukraine; DOB 27 Oct 1973; POB Luhansk, Ukraine; nationality Ukraine; Gender Male; Passport PU262444 (Ukraine); National ID No. CO168696 (Ukraine) (individual).

    PORTNOV, Andriy (a.k.a. PORTNOV, Andrij Volodymyrovych; a.k.a. PORTNOV, Andriy Volodymyrovych (Cyrillic:ПОРТНОВ, Андрій Володимирович)), Ukraine; DOB 27 Oct 1973; POB Luhansk, Ukraine; nationality Ukraine; Gender Male; Passport PU262444 (Ukraine); National ID No. CO168696 (Ukraine) (individual).

    ANDRIY PORTNOV FUND (Cyrillic: ФОНД АНДРІЯ ПОРТНОВА) (a.k.a. CHARITABLE ORGANIZATION ANDRIY PORTNOV FUND (Cyrillic: БЛАГОДІЙНА ОРГАНІЗАЦІЯ ФОНД АНДРІЯ ПОРТНОВА)), Yevhena Konoval’tsya Street, Building 36-B, Apartment 50, Kyiv 01133, Ukraine (Cyrillic: ВУЛИЦЯ ЄВГЕНА КОНОВАЛЬЦЯ, будинок 36-В, квартира 50, Київ 01133, Ukraine); Target Type Charity or Nonprofit Organization; Company Number 43465723 (Ukraine) (Linked To: PORTNOV, Andriy Volodymyrovych).

    CHARITABLE ORGANIZATION ANDRIY PORTNOV FUND (Cyrillic: БЛАГОДІЙНА ОРГАНІЗАЦІЯ ФОНД АНДРІЯ ПОРТНОВА) (a.k.a. ANDRIY PORTNOV FUND (Cyrillic: ФОНД АНДРІЯ ПОРТНОВА)), Yevhena Konoval’tsya Street, Building 36-B, Apartment 50, Kyiv 01133, Ukraine (Cyrillic: ВУЛИЦЯ ЄВГЕНА КОНОВАЛЬЦЯ, будинок 36-В, квартира 50, Київ 01133, Ukraine); Target Type Charity or Nonprofit Organization; Company Number 43465723 (Ukraine) (Linked To: PORTNOV, Andriy Volodymyrovych).

    OFAC Program: RUSSIA-EO14024 Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR Part 587; Executive Order 14024.

    DMITRIEV, Vladimir Aleksandrovich, Moscow, Russia; DOB 25 Aug 1953; POB Moscow, Russia; nationalityRussia; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024. (individual).

    VILLA, Frederic Pierre, Malta; DOB 21 Oct 1967; nationality Italy; alt. nationality Switzerland; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport X6107409 (Switzerland); alt. PassportYA6181234 (Italy) (individual) (Linked To: STRATTON INVESTMENT GROUP LTD).

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