Mr. Sanctions

Category: Russia

  • 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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  • 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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  • 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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  • OFSI Russia sanctions additions, reformatted

    Based on the Annex to Notice_Russia_041225.pdf, here are the additions to the consolidated list, reformatted as requested:

    Based on the Office of Financial Sanctions Implementation (OFSI) update provided, here are the additions to the Russia financial sanctions regime, reformatted as requested.

    Entities

    1. THE MAIN DIRECTORATE OF THE GENERAL STAFF OF THE ARMED FORCES OF THE RUSSIAN FEDERATION (GRU)

    • Group ID: 17235
    • Name (non-Latin script): Гла́вное управле́ние Генера́льного шта́ба Вооружённых сил Росси́йской Федера́ции
    • 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. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 04/12/2025. (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 or threatening the territorial integrity, sovereignty or independence of Ukraine.
    • Listed on: 04/12/2025 UK Sanctions List
    • Date Designated: 04/12/2025
    • Last Updated: 04/12/2025

    Supplemental Information: The GRU is Russia’s foreign military intelligence agency. This designation sanctions the agency in its entirety. The UK government stated this action was taken in response to the GRU’s “ongoing campaign of hostile activity,” including the 2018 Salisbury Novichok poisonings and malign activities across Europe and Ukraine.

    Individuals

    1. Yuriy Alekseevich SIZOV

    • Group ID: 17236
    • Name (non-Latin script): Юрий Алексеевич СИЗОВ
    • DOB: 17/02/1988
    • POB: St Petersburg, Russia
    • Nationality: Russia
    • National Identification Number: 784805190577
    • National Identification Details: Tax identification number1
    • Position: GRU officer2
    • Other Information: (UK Sanctions List Ref): RUS3150. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 04/12/2025. (UK Statement of Reasons): Yuriy Alekseevich SIZOV is an involved person under the Russia3 (Sanctions) (EU Exit) Regulations 2019 on the basis that he is or has been destabilising Ukraine or undermining the territorial security and sovereignty of Ukraine by engaging in, providing support for,4 or promoting actions which destabilise Ukraine or undermine or threaten the territorial 5integrity, sovereignty or ind6ependence of Ukraine.
    • (Gender): Male
    • Listed on: 04/12/2025 UK Sanctions List
    • Date Designated: 04/12/2025
    • Last Updated: 04/12/2025

    Supplemental Information: Yuriy Sizov is identified as a GRU officer. He is reported to be part of a team (Unit 29155) involved in organizing sabotage operations in Western countries, working in coordination with other sanctioned officers like Denis Smolyaninov.

    2. Vladimir LIPCHENKO

    • Group ID: 17237
    • Name (non-Latin script): Владимир ЛИПЧЕНКО
    • DOB: 28/09/1974
    • a.k.a: (1) VLODEK (2) WLODEK
    • Nationality: Russia
    • Passport Number: 4015400649
    • Passport Details: Russian passport number
    • Position: GRU officer
    • Other Information: (UK Sanctions List Ref): RUS3151. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 04/12/2025. (UK Statement of Reasons): Vladimir LIPCHENKO is an involved person under the Russia (Sanctions) (EU Exit) Regulations 2019 on the basis that he is or has been destabilising Ukraine or undermining the territorial secur7ity and sovereignty of Ukraine by engaging in, providing support for, or promoting actions which destabilise Ukraine or undermin8e or threa9ten the territorial integrity, sovereignty or independence of Ukraine.101112
    • (Gender): Male131415
    • Listed on: 04/12/2025 UK Sanctions List161718
    • Date Designated: 04/12/2025192021
    • Last Updated: 04/12/2025222324

    Supplemental Information: Vladimir Lipchenko is a GRU officer wh25o also uses the alias “Vlodek” (or Wlodek). Reports indicate he works under the command of Denis Smolyaninov and has been involved in orchestrating sabotag26e activiti27es in the West.

    3. Denis Alexandrovich SMOLYANINOV

    • Group ID: 17238
    • Name (non-Latin script): Денис Александрович СМОЛЯНИНОВ
    • Title: Colonel
    • DOB: 26/08/1976
    • POB: Chelyabinsk, Russia
    • Nationality: Russia
    • National Identification Number: 672904784466
    • National Identification Details: Tax identification number
    • Position: GRU officer
    • Other Information: (UK Sanctions List Ref): RUS3152. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 04/12/2025. (UK Statement of Reasons): Denis Alexandrovich SMOLYANINOV (hereafter SMOLYANINOV) is an involved person under the Russia (Sanctions) (EU Exit) Regulations 2019 on the basis that: a) SMOLYANINOV is or has28 been obtaining a benefit from the Government of Russia, and is involved in destabilising Ukraine or b) SMOLYANINOV is 29or ha30s been 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, namely the coordina31tion of hostile activities.32
    • (Gender): Male33
    • Listed on: 04/12/2025 UK Sanctions List34
    • Date Designated: 04/12/202535
    • Last Upd36ated: 04/12/2025

    Supplemental Information: Colonel Denis Smolyaninov is a high-ranking officer in the GRU’s Unit 29155. He has been accused by European intelligence agencies of recruiting “disposable agents” (often criminals) to carry out sabotage attacks, such as arson at DHL logistics hubs in the UK and Germany. He was also specifically named by the UK government as being responsible for plotting a terror attack on Ukrainian supermarkets.

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  • OFAC Penalty Imposition om Gracetown, Inc. – simplified

    Based on the Gracetown, Inc. enforcement action (released December 4, 2025), here is the reformatted and simplified summary.

    What Happened

    Gracetown, Inc., a property management company based in New York, has been fined approximately $7.1 million for severely violating US sanctions against Russia. (Note: this is not a negotiated settlement, but a financial penalty imposed on Gracetown)

    Between 2018 and 2020, Gracetown managed luxury real estate properties in New York and Washington, D.C. for Oleg Deripaska, a high-profile Russian oligarch. The company continued this work even after the US government designated Deripaska as a sanctioned person (an “SDN”) in 2018. Most notably, Gracetown ignored a specific written warning from OFAC telling them to stop. Instead of freezing the assets, they continued to collect payments and manage the properties, helping the oligarch maintain his lifestyle and assets in the US.

    The Penalty

    The Settlement Amount: $7,139,305

    How it was calculated:

    In most sanctions cases, the final penalty is significantly lower than the legal maximum. However, in this case, OFAC determined that the penalty should be near the statutory maximum.

    OFAC decided that Gracetown’s actions were “egregious” (a remarkably bad and willful violation of the law). Because of this, and because Gracetown did not confess to the government before getting caught, they faced the severe “statutory maximum” penalty rather than a negotiated lower amount.

    To arrive at the final figure, OFAC analyzed the “General Factors.” Because the violations were deemed “egregious” and were not voluntarily disclosed, the standard reductions that many companies receive were not applied.

    Aggravating and Mitigating Factors

    Aggravating Factors (What made the penalty higher)

    • Behavior: Gracetown received a direct “Notification of Blocked Property” from OFAC explicitly warning them that Deripaska was sanctioned and that they must stop dealing with him. They ignored this notice and continued their business relationship.
      • General Factor: Willful or Reckless Violation of Law
      • Applicability: Deliberately ignoring a specific government warning constitutes a “willful” violation, which is the most serious level of culpability and leads to the harshest penalties.
    • Behavior: The company’s management had full actual knowledge that they were managing properties for Deripaska and that he was a sanctioned individual.
      • General Factor: Management Involvement
      • Applicability: Violations are treated more severely when senior management is aware of the illegal conduct and approves or directs it.
    • Behavior: Gracetown failed to report that they were holding “blocked property” (the real estate) to OFAC for over 45 months, despite legal requirements to do so within 10 days.
      • General Factor: Cooperation with OFAC (Lack thereof)
      • Applicability: Concealing information or failing to file mandatory reports is viewed as a failure to cooperate and an attempt to hide violations.
    • Behavior: The company provided economic benefits to a high-priority target of US foreign policy (a Russian oligarch linked to the Kremlin), undermining the impact of the sanctions.
      • General Factor: Harm to Sanctions Program Objectives
      • Applicability: Providing significant assets or services to key sanctioned individuals is considered to cause substantial harm to US national security interests.

    Mitigating Factors (What lowered the penalty)

    • Behavior: Gracetown had not received a penalty notice or finding of violation from OFAC in the five years preceding the date of the transactions.
      • General Factor: Sanctions History
      • Applicability: OFAC considers a company’s clean record over the previous five years as a standard mitigating factor in calculating civil penalties.
    • Behavior: Gracetown cooperated with OFAC’s investigation by entering into agreements to extend the statute of limitations (tolling agreements) and responding to requests for information.
      • General Factor: Cooperation with OFAC
      • Applicability: Demonstrating a willingness to work with the government during the investigation—even if the violation itself was not self-disclosed—is typically a factor that weighs in favor of the subject.

    Despite the existence of these two mitigating factors, they had a limited impact on the final penalty amount. Because OFAC determined that Gracetown’s conduct was egregious—specifically noting the willful decision to ignore a direct government warning (“Notification of Blocked Property”)—the agency focused primarily on the statutory maximum penalty. In cases of egregious and willful violations, standard mitigating factors like a clean history or administrative cooperation are often insufficient to significantly reduce the fine, resulting in a penalty that remains near the legal limit.

    What are the Takeaways?

    Never Ignore a Government Warning

    If OFAC sends your company a letter, notice, or subpoena regarding a specific client or risk, you must act immediately. Ignoring a direct warning is the surest way to face maximum penalties and potential criminal liability.

    Property Management is “Dealing in Blocked Property”

    Managing real estate for a sanctioned person—collecting rent, paying utilities, or performing repairs—is illegal. You are effectively providing a service that helps a sanctioned person maintain their asset.

    You Must Report “Frozen” Assets

    If you discover you are holding property (like a house, apartment, or bank account) for a sanctioned person, you cannot just “do nothing.” You must officially report that property to OFAC as “blocked” within 10 days. Failing to report is a separate, serious violation.

    Gatekeepers are Targets

    OFAC and the DOJ are aggressively targeting “gatekeepers”—lawyers, property managers, and accountants—who help oligarchs hide their wealth. You cannot claim you are “just a service provider” if you know the ultimate owner is sanctioned.

    Other Resources

    For more information on the specific sanctions programs and guidelines mentioned:

    • OFAC Sanctions Lists: The official list of blocked persons (SDN List), which includes Oleg Deripaska.
    • Ukraine-/Russia-related Sanctions Regulations: The specific laws Gracetown violated, which prohibit any dealings with designated Russian oligarchs.
    • Economic Sanctions Enforcement Guidelines: The rulebook OFAC uses to determine if a case is “egregious” and to calculate the maximum penalty.

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  • Daily Digest for Thursday, December 4, 2025

    Daily Digests are simple lists of hyperlinks to new content released by sanctions and export control regulators. When appropriate, additional posts of analysis and commentary, as well as summarizations and rephrasing of the contents will be posted separately.

    Mr. Sanctions does not attempt to comprehensively cover the worlds of sanctions and export control. Opinions expressed here are my own and do not represent that of my past current or future employers.

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  • Burning Question about Executive Order 14024

    When Executive Order 14024 was issued by President Biden after the invasion of Ukraine by Russia, I noticed that more than a few authorities seemed very much like thiose in “activity-based’ or “conduct-based” sanctions programs – like the Election Interference and Cyber programs. I had always assumed it was a way of creating a “universe” of malign Russian government actions (although, to be fair, those programs’ designations are usually populated by state actors, whether from Iran, North Korea or otherwise), rather than a universe of actors performing the same bad acts, regardless of affiliation.

    So, I asked Gemini what it could find in online chatter:

    Online sources, legal analyses, and government statements indicate the Biden administration issued Executive Order (E.O.) 14024 (“Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation”) instead of modifying existing activity-based programs for several strategic, legal, and administrative reasons.1

    The core distinction is that E.O. 14024 creates a status-based authority (targeting actors based on who they are or where they operate), whereas the Election Interference (E.O. 13848) and Cyber (E.O. 13694/13757) programs are conduct-based (targeting actors based on what they did).

    Here is a breakdown of the specific reasons for this choice:

    1. Lower Burden of Proof (Status vs. Conduct)

    • Activity-Based Programs: To sanction someone under the Cyber or Election Interference E.O.s, the U.S. government must typically prove that a specific individual or entity engaged in, was complicit in, or materially supported a specific “bad act” (e.g., a specific hack or election influence campaign). Attribution in these areas can be technically difficult, slow, and classified.2
    • E.O. 14024: This order authorizes sanctions against persons simply for “operating in” specific sectors of the Russian economy (e.g., technology, defense, financial services).3 This allows the government to designate targets based on their presence in a high-risk sector without needing to publicly prove their direct involvement in a specific cyberattack or election scheme. This creates a much faster and more flexible designation process.

    2. Targeting the “Ecosystem” and Supply Chain

    • Broader Reach: Existing activity-based sanctions often target the “tip of the spear”—the hackers or operatives directly carrying out attacks. E.O. 14024 was designed to target the broader ecosystem that supports them.
    • Sectoral Authority: By authorizing sanctions on the Russian technology and defense sectors, the administration could target the companies that build the tools, provide the infrastructure, and fund the intelligence services that conduct these malign activities, even if those companies didn’t launch the attacks themselves.4

    3. Consolidation and Modernization

    • Unified Framework: Prior to E.O. 14024, responding to Russian aggression required a patchwork of authorities (some for Ukraine, some for Cyber, some for Election Interference, etc.). E.O. 14024 consolidated these into a single “Russian Harmful Foreign Activities” program.
    • Comprehensive “National Emergency”: The order declares a distinct national emergency focused specifically on the totality of the Russian government’s malign behavior.5 This allows for a more holistic response where a single designation can cite multiple types of bad conduct (e.g., a target involved in both cyber espionage and election interference) under one legal roof.6

    4. “Sword of Damocles” (Flexibility for Future Escalation)7

    • Scalability: E.O. 14024 was written with built-in flexibility. It allows the Secretary of the Treasury (in consultation with the Secretary of State) to identify new sectors of the Russian economy for sanctions at any time without the President needing to sign a new Executive Order.8
    • Deterrence: This structure serves as a standing threat that the U.S. can rapidly expand sanctions to other parts of the Russian economy (e.g., energy, mining, financial services) if Russian behavior continues or escalates.9

    5. Attribution to the State

    • Political Messaging: Activity-based sanctions like E.O. 13694 are global and country-agnostic—they apply to hackers in China, Iran, or North Korea equally. By issuing a Russia-specific order, the administration sent a diplomatic signal attributing these activities directly to the Government of the Russian Federation, framing them not as isolated crimes but as state-directed policy.10

    Footnotes for Executive Order 14024 Analysis

    1. Lower Burden of Proof (Status vs. Conduct)

    • Status-Based Authority: E.O. 14024 allows for the imposition of sanctions on individuals and entities determined to “operate or have operated in the technology sector or the defense and related materiel sector of the Russian Federation economy” (Section 1(a)(i)).1 This is a “status-based” authority, meaning designation is based on the target’s position within a sector rather than specific evidence of a malicious act.^1
    • Conduct-Based Limitations: In contrast, the Cyber Sanctions program (E.O. 13694, as amended) requires the government to determine that a person is “responsible for or complicit in” specific cyber-enabled activities that harm national security.^2 Similarly, the Election Interference program (E.O. 13848) requires a determination that a person has “directly or indirectly engaged in, sponsored, concealed, or otherwise been complicit in” foreign interference in a U.S. election.^3

    2. Targeting the “Ecosystem” and Supply Chain

    • Sectoral Targeting: The Biden administration stated that E.O. 14024 was designed to target the “ecosystem” supporting Russia’s malign activities. By designating the technology and defense sectors, the order enables the Treasury to sanction companies that procure technology or manufacture components for the Russian intelligence services, even if those companies do not execute the attacks themselves.^4
    • Supply Chain Disruption: Legal analysts note that this approach moves beyond the “tip of the spear” (the hackers) to the supply chain, allowing the U.S. to degrade the Russian government’s capabilities by cutting off access to western financial markets and technology for broad swaths of the Russian economy.^5

    3. Consolidation and Modernization

    • Unified Framework: Prior to E.O. 14024, sanctions authorities were fragmented across multiple emergency declarations (e.g., Ukraine-specific E.O. 13660, Cyber E.O. 13694, Election E.O. 13848). E.O. 14024 declares a new, comprehensive national emergency with respect to “specified harmful foreign activities of the Government of the Russian Federation,” creating a single legal chassis to address election interference, cyberattacks, transnational corruption, and extraterritorial activities.^6
    • Holistic Response: This consolidation allows OFAC to cite multiple bases for a single designation, simplifying the administrative record and strengthening the legal defense of the designation if challenged in court.^7

    4. “Sword of Damocles” (Flexibility for Future Escalation)2

    • Scalability: The order grants the Secretary of the Treasury, in consultation with the Secretary of State, the authority to expand sanctions to any sector of the Russian economy without a new presidential order.^8 This was explicitly designed to provide “flexibility” and leverage, allowing the administration to ratchet up pressure by targeting additional sectors (as it later did with financial services, energy, and others following the 2022 invasion of Ukraine).^93

    5. Attribution to the State

    • State-Directed Policy: The title of the order itself—”Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation“—is a deliberate diplomatic signal. Unlike the country-agnostic Cyber or Election orders, this order formally attributes these behaviors (SolarWinds, 2020 election interference) to the Russian state as a matter of U.S. policy.^10

    Source References:

    ^1 Executive Order 14024, Federal Register, Vol. 86, No. 73 (April 19, 2021).

    ^2 Executive Order 13694, “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities” (April 1, 2015).4

    ^3 Executive Order 13848, “Imposing Certain Sanctions in the Event of Foreign Interference in a United States Election” (September 12, 2018).5

    ^4 White House Fact Sheet, “Imposing Costs for Harmful Foreign Activities by the Russian Government” (April 15, 2021).

    ^5 See, e.g., Miller & Chevalier, “Trade Compliance Flash: New Executive Order Expands Sanctions Risk in Russia” (April 21, 2021).6

    ^6 Id.

    ^7 Congressional Research Service, “U.S. Sanctions on Russia: Legal Authorities and Related Actions” (Updated 2024).

    ^8 Executive Order 14024, Section 1(a)(i).7

    ^9 Skadden, Arps, Slate, Meagher & Flom LLP, “US Imposes Additional Round of Sanctions on Russia” (April 22, 2021).8

    ^10 Id.

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  • OFAC’s Settlement with IPI Partners, LLC

    See the original Enforcement Release for comparison or if you want to know more.

    Based on the enforcement release regarding IPI Partners, LLC (“IPI”), here is the simplified and reformatted version.

    What Happened

    The Core Issue

    IPI Partners, LLC (“IPI”), a U.S. private equity firm, agreed to pay $11,485,352 to settle potential civil liability for violating U.S. sanctions against Russia. The issue arose because IPI continued to do business involving Suleiman Kerimov, a Russian oligarch, even after he was placed on the sanctions list (the “SDN List”).

    Description of the Conduct

    In 2017 and 2018, IPI sought and accepted investment funds from Kerimov through a series of legal entities (specifically a fund called “Definition” and a trust called “Heritage Trust”).

    • The Red Flag: On April 6, 2018, OFAC designated Kerimov as a sanctioned person. This meant U.S. companies were generally prohibited from dealing with his property or interests.
    • The Legal Advice: IPI checked with outside lawyers. The lawyers reviewed the corporate structure and concluded that because Kerimov did not formally own 50% or more of the direct investment entity (“Definition”), IPI did not need to block the account.
    • The Mistake: This advice was too narrow. While Kerimov might not have met the “50% ownership” threshold for automatic blocking of the entity itself, he still held a “property interest” in the funds (as the source of funds and beneficiary). U.S. law prohibits dealing with any property interest of a blocked person, not just entities they majority-own.
    • The Violation: Relying on that advice, IPI continued to manage the investment. Between July 2018 and June 2022, IPI processed 51 transactions (such as calling for capital or distributing profits) involving these funds.

    The Penalty

    Settlement Amount

    IPI agreed to pay $11,485,352. The maximum possible base penalty for these violations was $14,356,690.

    Why this Amount? (The Rationale)

    The settlement reflects OFAC’s determination that the violations were non-egregious (meaning they were not the most serious type of willful violation) but were not voluntarily self-disclosed (IPI did not report the issue to OFAC before being investigated).

    Factors Influencing the Penalty

    OFAC considered several “General Factors” from its Enforcement Guidelines to determine the final penalty amount:

    • Aggravating Factors (Reasons the penalty could be higher):
      • IPI knew or had reason to know of the sanctioned person’s involvement. IPI was aware that Kerimov was the ultimate source of the funds but failed to exercise due caution, relying on legal advice that focused only on ownership percentages rather than the broader “interest in property.”
        • Applicable General Factor: General Factor B: Awareness of Conduct
      • The conduct harmed the sanctions program. By continuing to process transactions for a sanctioned oligarch, IPI allowed economic resources to flow to a blocked person, undermining the purpose of the Russia sanctions program.
        • Applicable General Factor: General Factor C: Harm to Sanctions Program Objectives
      • IPI is a sophisticated financial institution. IPI is a large, commercially sophisticated firm with a global presence and access to significant legal and compliance resources. OFAC holds such institutions to a higher standard of compliance.
        • Applicable General Factor: General Factor D: Individual Characteristics
    • Mitigating Factors (Reasons the penalty was reduced):
      • No recent violations. IPI had not received a penalty notice or finding of violation from OFAC in the five years preceding these transactions.
        • Applicable General Factor: General Factor E: Compliance Program (often cited regarding clean history) / General Factor I: Other Enforcement Actions
      • Substantial cooperation. After initially providing unsatisfactory responses, IPI hired new counsel, significantly improved its cooperation, and even waived attorney-client privilege to allow OFAC to review the legal advice it had received.
        • Applicable General Factor: General Factor G: Cooperation with OFAC
      • Remedial measures. IPI took steps to fix the issue and improve its compliance program to prevent future violations.
        • Applicable General Factor: General Factor F: Remedial Response

    What are the Takeaways?

    Key Lessons for the Industry

    • Look Beyond the “50% Rule”: Dealing with a sanctioned person involves more than just checking if they own 50% of a company. You must ensure you are not dealing with any “interest” of a blocked person, including indirect interests through trusts or as a beneficiary.
    • Private Equity Risks: Investment firms must thoroughly understand the ownership structure of their investors (“Limited Partners”). If a sanctioned person is behind the money, you cannot process transactions for them, even through intermediaries.
    • Legal Advice Limitations: Relying on legal advice is not a “get out of jail free” card, especially if that advice is based on an incomplete understanding of the facts or a misinterpretation of the broad scope of sanctions laws (like “interest in property”).
    • Know Your Customer (KYC): It is critical to obtain and review full diligence materials to identify the ultimate beneficial owners of investment vehicles.

    Other resources

    Reporting Suspicious Activity

    If you have information about sanctions violations, you may be eligible for a monetary award. The Financial Crimes Enforcement Network (FinCEN) maintains a Whistleblower Program that rewards individuals who provide original information leading to successful enforcement actions. You can submit tips directly to FinCEN or through OFAC.

    Contacting OFAC

    For more information on sanctions programs, specific guidance, or to join the mailing list for updates, you can contact the Office of Foreign Assets Control directly via their compliance hotline or compliance email, or by visiting the official Treasury website.

    How do you like this revamped format? I will tell you, this took more tweaking than some of the other posts I’ve done so far – Gemini originally left off the 3rd Aggravating Factor from its analysis (weird, huh?), and I had some formatting issues that I fixed by being explicit in the prompt. And then I had to wrestle it to remove external links it added…

    If there are things from the actual Enforcement Release you think should have been in this reimagined format – or if you see something it got wrong – please let me know. Thanks!

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