Category Archives: Crimea Ukraine sanctions

Crimea Ukraine sanctions

07.31.15
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July 30, 2015: OFAC issues Crimea sanctions evasion advisory

Surprise! People are trying to evade the Crimean sanctions (from Executive Order 13685) from OFAC by omitting or oscuring references to Crimea. OFAC has issued an advisory highlighting the practices it has noticed, including:

In the context of financial transactions, OFAC has become aware that certain individuals or entitieshave engaged in a pattern or practice of repeatedly omitting originator or beneficiary addressinformation from Society for Worldwide Interbank Financial Telecommunications (SWIFT)messages involving individuals ordinarily resident in, or entities located in, Crimea (collectively,”Crimean individuals or entities”). Some SWIFT messages omit all originator or beneficiary addressinformation while other payment messages contain only partial address information for Crimeanindividuals or entities, including, for example, a street address but no reference to a town, city,region, or country. Financial institutions have discovered the data missing from these SWIFTmessages through enhanced due diligence efforts performed on one of the transaction parties afteridentifying a suspicious Crimea-related pattern or practice.

OFAC has also included a section of controls that firms should have in place to stay compliant with the very general Crimean sanctions, including:

  • Ensuring that transaction monitoring systems include appropriate search terms correspondingto major geographic locations in Crimea and not simply references to “Crimea.” Forexample, payment instructions or trade documents may reference major cities or ports locatedin Crimea, and interdiction filters may not flag such transactions for review if the filters donot include an appropriately expansive list of search terms.
  • Requesting additional information from parties (including financial institutions, corporateentities, and individuals) that previously have violated or attempted to violate U.S. sanctionson Crimea. Such prior conduct could include, for example, routing transactions to or throughU.S. financial institutions with inaccurate or incomplete address information for Crimeanindividuals or entities.
  • Clearly communicating U.S. sanctions obligations to international partners (in both thefinancial and trade sectors) and discussing OFAC sanctions compliance expectations withcorrespondent banking and trade partners. Such communications should include, forexample, a description of the prohibition on the direct and indirect exportation orreexportation of goods, technology, and services (including financial services) from theUnited States to Crimea.

Links:

OFAC Notice

Crimea Sanctions Advisory

Executive Order 13685

 

07.31.15
by

July 30, 2015: OFAC makes Ukraine/Crimea SDN and SSI additions, Cote d’Ivoire removals

Yesterday, OFAC added the following people to the SDN List under the Ukraine-related sanctions program:

BULYUTIN, Andrey, London, United Kingdom; DOB 19 Oct 1979; POB Izhevsk, Russia; citizen Russia; Passport 515356705 (Russia); Business Development Manager at Kalashnikov Concern (individual) [UKRAINE-EO13661].
KLYUYEV, Andriy Petrovych (a.k.a. KLIUIEV, Andrii Petrovych; a.k.a. KLUEV, Andriy; a.k.a. KLYUEV, Andriy; a.k.a. KLYUYEV, Andrey); DOB 12 Aug 1964; POB Donetsk, Ukraine (individual) [UKRAINE-EO13660].
KOLBIN, Petr (a.k.a. KOLBIN, Peter; a.k.a. KOLBIN, Petr Viktorovich; a.k.a. KOLBIN, Pyotr); DOB 02 Jan 1952; POB Russia (individual) [UKRAINE-EO13661].
KURCHENKO, Sergey Vitalievich (a.k.a. KURCHENKO, Sergei; a.k.a. KURCHENKO, Sergii; a.k.a. KURCHENKO, Serhiy; a.k.a. KURCHENKO, Serhiy Vitaliyovych); DOB 21 Sep 1985 (individual) [UKRAINE-EO13660].
OMELCHENKO, Aleksander (a.k.a. OMELCHENKO, Aleksandr Anatolyevich; a.k.a. OMELCHENKO, Alexander A.; a.k.a. OMELCHENKO, Alexander Anatolyevich; a.k.a. OMELCHENKO, Alexandr Anatolyevich); DOB 08 Sep 1983; POB Moscow, Russia; citizen Russia; Passport 721937258 (Russia); National ID No. 4598338396 (Russia); alt. National ID No. 4506978162 (Russia); Chief Export Officer for Kalashnikov Concern (individual) [UKRAINE-EO13661].
PAANANEN, Kai (a.k.a. PAANANEN, Kai Lauri Johannes); DOB 21 Jul 1954; Chairman, SET Petrochemicals Oy; Managing Director, Southeast Trading Oy (individual) [UKRAINE-EO13661].
ROTENBERG, Roman, Beregovaya, Street 6, Apartment 25, Moscow 125367, Russia; DOB 07 Apr 1981; citizen Russia; alt. citizen Finland; Passport 640848350 (Russia); alt. Passport 16038132 (Finland); alt. Passport 17017258 (Finland) (individual) [UKRAINE-EO13661].
SEMENOVA, Olena Yurevna (a.k.a. SEMENOVA, Elena Iurevna); DOB 06 Dec 1978; citizen Ukraine; Passport ER747251 (Ukraine); National ID No. 2882908207 (Ukraine) (individual) [UKRAINE-EO13661].
STAVYTSKY, Eduard Anatoliyovych (a.k.a. STAVYTSKYI, Eduard; a.k.a. STAVYTSKYY, Eduard); DOB 04 Oct 1972; POB Lebedyn, Ukraine; citizen Ukraine; alt. citizen Israel (individual) [UKRAINE-EO13660].
USACHEV, Oleg (a.k.a. USACHEV, Oleg Leonidovich); DOB 03 Jul 1970 (individual) [UKRAINE-EO13661].
YANUKOVYCH, Oleksandr Viktorovych (a.k.a. YANUKOVICH, Alexander; a.k.a. YANUKOVICH, Oleksander; a.k.a. YANUKOVYCH, Aleksandr Viktorovych; a.k.a. YANUKOVYCH, Olexander); DOB 01 Jul 1973; POB Donetsk, Ukraine (individual) [UKRAINE-EO13660].

Two things to note here. First, there are designations both under Executive Order 13660 (the original one against former Ukrainian officials) and 13661 (against Russian officials). Second, I note that Roman Rotenberg was designated – his relatives transferred some of their assets, including an arena in Finland, to him to avoid sanctions some months ago.

OFAC also added the following entities under the Ukraine-related and Crimea (Executive Order 13685) sanctions:

AIRFIX AVIATION OY, Tullimiehentie 4-6, Vantaa 01530, Finland; Chemin des Papillons 4, Geneva/Cointrin 1216, Switzerland [UKRAINE-EO13661].
IPP OIL PRODUCTS (CYPRUS) LIMITED, 12 Esperidon Street, 4th Floor, Nicosia 1087, Cyprus; Public Registration Number C210706 [UKRAINE-EO13661].
IZHEVSKY MEKHANICHESKY ZAVOD JSC (a.k.a. BAIKAL), 8 Promyshlennaya Str., Izhevsk 426063, Russia; Website http://www.baikalinc.ru [UKRAINE-EO13661].
OPEN JOINT STOCK COMPANY “KONTSERN IZHMASH” (a.k.a. OJSC KONTSERN IZHMASH), 3 Deryabin Proezd, Izhevsk, Udmurt Republic 426006, Russia; Public Registration Number 1021801434380 [UKRAINE-EO13661].
OY LANGVIK CAPITAL LTD, Tanskarlantie 9, Jorvas 02420, Finland; National ID No. 19607726 [UKRAINE-EO13661].
PRIVATE JOINT-STOCK COMPANY MAKO HOLDING (a.k.a. MAKO HOLDING), Bohdan Khmelnytsky Avenue, Building 102, Voroshilovsky District, Donetsk, Donetsk Oblast 83015, Ukraine; Website http://mako.ua/; Email Address a.kyzura@mako-holding.com; Government Gazette Number 34436105 (Ukraine) [UKRAINE-EO13660] (Linked To: YANUKOVYCH, Oleksandr Viktorovych).
SET PETROCHEMICALS OY, Ukonvaaja 2 A, Espoo 02130, Finland [UKRAINE-EO13661].
SOUTHEAST TRADING OY (a.k.a. SOUTHEAST TRADING LTD), Bucharest, Romania; St. Petersburg, Russia; Espoo, Finland; Kannelkatu 8, Lappeenranta 53100, Finland; PL 148, Lappeenranta 53101, Finland [UKRAINE-EO13661].
SOUTHPORT MANAGEMENT SERVICES LIMITED, De Castro Street 24, Akara Building, Wickhams Cay 1, Road Town, Tortola, Virgin Islands, British; Nicosia, Cyprus [UKRAINE-EO13661].
STATE ENTERPRISE EVPATORIA SEA COMMERCIAL PORT (a.k.a. PORT OF EVPATORIA; a.k.a. PORT OF YEVPATORIA; a.k.a. SEAPORT OF YEVPATORIYA; a.k.a. YEVPATORIA COMMERCIAL SEAPORT; a.k.a. YEVPATORIA MERCHANT SEA PORT; a.k.a. YEVPATORIA SEA PORT; a.k.a. YEVPATORIYA COMMERCIAL SEA PORT; a.k.a. YEVPATORIYA SEA PORT), Mariners Square 1, Evpatoria, Crimea 97416, Ukraine; 1, Moryakov Sq, Yevpatoriya, Crimea 97408, Ukraine; 1 Moryakov Sq., Yevpatoria, Crimea 97416, Ukraine; Ukraine; 1 Moryakov Sq, Yevpatoriya, Crimea 97416, Ukraine; Email Address lada1@seavenue.net; alt. Email Address zamves@emtp.com.ua; UN/LOCODE UA ZKA; Registration ID 01125583 (Ukraine) [UKRAINE-EO13685].
STATE ENTERPRISE FEODOSIA SEA TRADING PORT (a.k.a. PORT OF FEODOSIA; a.k.a. SEAPORT OF FEODOSIYA; a.k.a. THEODOSIA COMMERCIAL SEAPORT; a.k.a. THEODOSIA MERCHANT SEA PORT; a.k.a. THEODOSIA SEA PORT), 14 Gorky Street, Theodosia 98100, Ukraine; 14, Gorky Str., Feodosiya, Crimea 98100, Ukraine; Gorky Street 11, Feodosia, Crimea 98100, Ukraine; Website http://www.ukrport.org.ua; Email Address theodosia@port.kafa.crimea.ua; UN/LOCODE UA FEO; Registration ID 01125577 (Russia) [UKRAINE-EO13685].
STATE ENTERPRISE KERCH SEA COMMERCIAL PORT (a.k.a. KERCH COMMERCIAL SEAPORT; a.k.a. KERCH MERCHANT SEA PORT; a.k.a. KERCH SEA PORT; a.k.a. PORT OF KERCH; a.k.a. SEAPORT OF KERCH; a.k.a. STATE ENTERPRISE KERCH COMMERCIAL SEA PORT), Kirova Street 28, Kerch, Crimea 98312, Ukraine; 28 Kirova Str., Kerch, Crimea 98312, Ukraine; 28, Kirov Str., Kerch, Crimea 98312, Ukraine; Ul. Kirov, 28, Kerch, Crimea 98312, Ukraine; ul Kirova 28, Kerch 98312, Ukraine; Website http://www.kerchport.com; alt. Website http://www.ukrport.org.ua; Email Address kmtp@kerch.sf.ukrtel.net; alt. Email Address referent.port@mail.ru; alt. Email Address kmtp@trport.kerch.crimea.com; UN/LOCODE UA KEH; Registration ID 01125554[UKRAINE-EO13685].
STATE ENTERPRISE SEVASTOPOL SEA TRADING PORT (a.k.a. PORT OF SEVASTOPOL; a.k.a. SEAPORT OF SEVASTOPOL; a.k.a. SEVASTOPOL COMMERCIAL SEAPORT; a.k.a. SEVASTOPOL MERCHANT SEA PORT; a.k.a. SEVASTOPOL SEA PORT; a.k.a. SEVASTOPOL SEA TRADE PORT; a.k.a. STATE ENTERPRISE SEVASTOPOL COMMERCIAL SEAPORT), 3 Place Nakhimova, Sevastopol 99011, Ukraine; 5, Nakhimova square, Sevastopol, Crimea 99011, Ukraine; Nahimova Square 5, Sevastopol, Crimea 99011, Ukraine; Email Address Sevport@stel.sebastopol.ua; alt. Email Address sevampu@ukr.net; alt. Email Address mail@morport.sebastopol.ua; UN/LOCODE UA SVP; Registration ID 01125548 (Ukraine) [UKRAINE-EO13685].
STATE ENTERPRISE YALTA SEA TRADING PORT (a.k.a. PORT OF YALTA; a.k.a. SEAPORT OF YALTA; a.k.a. YALTA COMMERCIAL SEAPORT; a.k.a. YALTA MERCHANT SEA PORT; a.k.a. YALTA SEA PORT), Roosevelt Street 3, Yalta, Crimea 98600, Ukraine; 5, Roosevelt Str., Yalta, Crimea 98600, Ukraine; 5 Roosevelt Street, Yalta, Crimea 98600, Ukraine; Website yaltaport.com.ua; Email Address yasko@ukrpost.ua; alt. Email Address yasco@mail.ylt.crimea.com; UN/LOCODE UA YAL; Registration ID 01125591 (Ukraine) [UKRAINE-EO13685].
STATE SHIPPING COMPANY KERCH SEA FERRY (a.k.a. STATE FERRY ENTERPRISE KERCH FERRY), Tselimbernaya Street 16, Kerch, Crimea 98307, Ukraine; 16 Tselibernaya Street, Kerch, Crimea 98307, Ukraine; Registration ID 14333981 (Ukraine) [UKRAINE-EO13685].

The six shipping companies are the first designations since Russian National Commercial Bank was added a while ago.

OFAC also added the following 35 companies to the Sectoral Sanctions Identification (SSI) List:

BANK BELVEB OJSC (a.k.a. BELVESHECONOMBANK OAO; a.k.a. BELVNESHECONOMBANK OPEN JOINT STOCK COMPANY), 29 Pobeditelei ave., Minsk 220004, Belarus; SWIFT/BIC BELB BY 2X; Website bveb.by; Executive Order 13662 Directive Determination – Subject to Directive 1; All offices worldwide; for more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
CJSC VANKORNEFT (a.k.a. VANKORNEFT; a.k.a. ZAO VANKORNEFT), Dobrovolcheskoy Brigady St., 15, Krasnoyarsk Territory 660077, Russia; Email Address info@vankoroil.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
DEVELOPMENT CORPORATION OF NORTH CAUCASUS OJSC (f.k.a. KRSK, OAO; a.k.a. OJSC NORTH CAUCASUS DEVELOPMENT CORPORATION; a.k.a. OPEN JOINT-STOCK COMPANY NORTH CAUCASUS DEVELOPMENT CORPORATION; a.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO KORPORATSIYA RAZVITIYA SEVERNOGO KAVKAZA), d. 139 ul. Pyatigorskaya Essentuki, Stavropolski krai 357625, Russia; Website krskfo.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1102632003253; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
EXIAR (a.k.a. EKSAR OAO; a.k.a. EXIAR OJSC; a.k.a. ROSSISKOE AGENTSTVO PO STRAKHOVANIYU EKSPORTNYKH KREDITOV I INVESTITSI OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. RUSSIAN AGENCY FOR EXPORT CREDIT AND INVESTMENT INSURANCE OJSC), str. 1 3 1-i Zachatievski per, Moscow, 119034, Russia; Website exiar.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1117746811566; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
EXIMBANK OF RUSSIA (a.k.a. GOSUDARSTVENNY SPETSIALIZIROVANNY ROSSISKI EKSPORTNO-IMPORTNY BANK (ZAKRYTOE AKTSIONERNOE OBSHCHESTVO); a.k.a. ROSEKSIMBANK, ZAO; a.k.a. RUSSIAN EXPORT-IMPORT BANK; a.k.a. STATE SPECIALIZED RUSSIAN EXPORT-IMPORT BANK (CLOSED JOINT-STOCK COMPANY)), d.13 str. 1 per.3-I Neopalimovski, Moscow 119121, Russia; SWIFT/BIC EXIR RU MM; Website eximbank.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1027739109133; All offices worldwide; for more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
FAR EAST AND BAIKAL REGION DEVELOPMENT FUND OJSC (a.k.a. FOND RAZVITIYA DALNEGO VOSTOKA I BAIKALSKOGO REGIONA, OAO; a.k.a. OJSC THE FAR EAST AND BAIKAL REGION DEVELOPMENT FUND; a.k.a. OPEN JOINT-STOCK COMPANY THE FAR EAST AND BAIKAL REGION DEVELOPMENT FUND; a.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO FOND RAZVITIYA DALNEGO VOSTOKA I BAIKALSKOGO REGIONA), d. 82 str. 2 ul. Sadovnicheskaya, Moscow 115035, Russia; Website fondvostok.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1112721010995; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
FEDERAL CENTER FOR PROJECT FINANCE (a.k.a. FTSPF, OAO; a.k.a. OAO FEDERALNY TSENTR PROEKTNOGO FINANSIROVANIYA; f.k.a. ZAKRYTOE AKTSIONERNOE OBSHCHESTVO FEDERALNY CENTR PROEKTNOGO FINANSIROVANIYA; a.k.a. “FCPF”), d. 14 prospekt Olimpiski, Moscow 129090, Russia; Website fcpf.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1027739088410; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
GLOBEXBANK (a.k.a. AKTSIONERNOE OBSHCHESTVO KOMMERCHESKI BANK GLOBEKS; f.k.a. CJSC GLOBEXBANK; a.k.a. GLOBEKSBANK, AO; a.k.a. GLOBEX COMMERCIAL BANK, JOINT STOCK COMPANY; f.k.a. ZAKRYTOE AKTSIONERNOE OBSHCHESTVO KOMMERCHESKI BANK GLOBEKS), d. 59 str. 2 ul. Zemlyanoi Val, Moscow 109004, Russia; SWIFT/BIC GLOB RU MM; Website globexbank.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1027739326010; All offices worldwide; for more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
KRASLESINVEST CJSC (a.k.a. CJSC KRASLESINVEST; a.k.a. KRASLESINVEST, ZAO; a.k.a. THE CLOSED JOINT-STOCK COMPANY KRASLESINVEST; a.k.a. ZAKRYTOE AKTSIONERNOE OBSHCHESTVO KRASLESINVEST), d. 35 A ul. Partizana Zheleznyaka, Krasnoyarsk, Krasnoyarski krai 660022, Russia; Website kraslesinvest.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1082468004574; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
NEFT-AKTIV LLC (a.k.a. OOO NEFT-AKTIV; a.k.a. RN-AKTIV OOO), Ulica Kaluzhskaya M., d., 15, str. 28, Moscow 119071, Russia; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC ACHINSK REFINERY (a.k.a. ACHINSK REFINERY; a.k.a. OAO ACHINSK OIL REFINERY VNK), Achinsk Refinery industrial area, Bolsheuluisky district, Krasnoyarsk territory 662110, Russia; Email Address sekr1@anpz.rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC ANGARSK PETROCHEMICAL COMPANY (a.k.a. ANGARSK REFINERY), Angarsk, Irkutsk region 665830, Russia; 6 ul. K. Marksa, Angarsk 665830, Russia; Website http://www.anhk.ru; Email Address delo@anhk.rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC KUYBYSHEV REFINERY (a.k.a. KUIBYSHEV REFINERY; a.k.a. OJSC KUIBYSHEV REFINERY), 25 Groznenskaya st., Samara 443004, Russia; Email Address sekr@knpz.rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC NOVOKUYBYSHEV REFINERY (a.k.a. NOVOKUIBYSHEVSK REFINERY; a.k.a. OJSC NOVOKUYBYSHEV REFINERY), Novokuibyshevsk, Samara region 446207, Russia; Email Address sekr@nknpz.rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC ORENBURGNEFT (a.k.a. OAO JSC ORENBURGNEFT; a.k.a. ORENBURGNEFT), Magistralnaya St., 2, Buzuluk, the Orenburg Region 461040, Russia; st. Magistralynaya 2, Buzuluk 461040, Russia; Email Address orenburgneft@rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC RN HOLDING (a.k.a. RN HOLDING OAO), 60 Oktyabrskaya ul., Uvat 626170, Russia; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; Registration ID 1047200153770 (Russia); Tax ID No. 7225004092 (Russia); Government Gazette Number 74743120 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC RUSSIAN REGIONAL DEVELOPMENT BANK (a.k.a. RUSSIAN REGIONAL DEVELOPMENT BANK; a.k.a. “VBRR”), 65/1 Suschevsky Val, Moscow 129594, Russia; 65 Sushchevskiy val, Moscow 129594, Russia; Website http://www.vbrr.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; Registration ID 3287 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC SAMOTLORNEFTEGAZ (a.k.a. SAMOTLORNEFTEGAZ; a.k.a. SAMOTLORNEFTEGAZ JSC), Lenina St. 4, the Tyumen Region, Khanty-Mansiysk, Autonomous District, Nizhnevartovsk 628606, Russia; Email Address NVSNGinfo@rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
OJSC SYZRAN REFINERY (a.k.a. OPEN JOINT-STOCK OIL AND GAS COMPANY SYZRAN; a.k.a. SYZRAN REFINERY), 1 Astrakhanskaya st., Syzran, Samara region 446009, Russia; Moskvorechje street 105, Building 8, Moscow 115523, Russia; Email Address sekr@snpz.rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
PJSC VERKHNECHONSKNEFTEGAZ (a.k.a. OJSC VERKHNECHONSKNEFTEGAZ; a.k.a. VERKHNECHONSKNEFTEGAZ), Baikalskaya St., 295 B, Irkutsk 664050, Russia; Email Address vcng@rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
PROMINVESTBANK (a.k.a. COMMERCIAL INDUSTRIAL AND INVESTMENT BANK PUBLIC JOINT STOCK COMPANY; a.k.a. JOINT STOCK COMMERCIAL INDUSTRIAL AND INVESTMENT BANK PUBLIC JOINT STOCK COMPANY; a.k.a. PSC PROMINVESTBANK; a.k.a. PUBLIC STOCK COMPANY JOINT STOCK COMMERCIAL INDUSTRIAL & INVESTMENT BANK), 12, Shevchenko lane, Kyiv 01001, Ukraine; SWIFT/BIC UPIB UA UX; Website pib.com.ua; Executive Order 13662 Directive Determination – Subject to Directive 1; All offices worldwide; for more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
RESAD LLC (a.k.a. LLC RESAD; a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU RESAD; a.k.a. RESAD, OOO), d. 5 ul. Bryanskaya, Moscow 121059, Russia; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1027739071337; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
RN-KOMSOMOLSKY REFINERY LLC (a.k.a. KOMSOMOLSK REFINERY; a.k.a. LLC RN-KOMSOMOLSK REFINERY; a.k.a. RN-KOMSOMOLSKI NPZ OOO), 115 Leningradskaya st., Komsomolsk-on-Amur, Khabarovsk region 681007, Russia; Email Address knpz@rosneft.ru; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
RN-YUGANSKNEFTEGAZ LLC (a.k.a. RN-YUGANSKNEFTEGAZ OOO; a.k.a. YUGANSKNEFTEGAZ), Lenina St., 26, Nefteyugansk, Tyumen Region 628309, Russia; Email Address rn_yng@yungjsc.com; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
ROSE GROUP LIMITED (f.k.a. RGI INTERNATIONAL; f.k.a. RGI INTERNATIONAL LIMITED; a.k.a. “ROSE GROUP”), Frances House, Sir William Place, St. Peter Port GY1 4EU, Guernsey; Korobeinikov Lane, 1, Moscow 119034, Russia; Website rosegroup.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
ROSNEFT FINANCE S.A., 46A Avenue John F Kennedy, 2nd Floor, Luxembourg 1855, Luxembourg; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
ROSNEFT TRADE LIMITED (f.k.a. TNK TRADE LIMITED), Elenion Building 5 Themistokli Dervi, 2nd floor, Lefkosia, Nicosia 1066, Cyprus; Email Address hrm@rosneft-sh.com.cy; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; Registration ID C122790; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
ROSNEFT TRADING S.A., 2, Rue Place du Lac, 1204, Geneva, Switzerland; Website http://www.rosneft.com; Executive Order 13662 Directive Determination – Subject to Directive 2; alt. Executive Order 13662 Directive Determination – Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY).
RUSSIAN DIRECT INVESTMENT FUND MANAGEMENT COMPANY (a.k.a. LIMITED LIABILITY COMPANY RDIF MANAGEMENT COMPANY; a.k.a. MANAGEMENT COMPANY RDIF LLC; a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU UPRAVLYAYUSHCHAYA KOMPANIYA RFPI; a.k.a. RDIF MANAGEMENT COMPANY; a.k.a. RDIF MANAGEMENT COMPANY LLC; a.k.a. UK RFPI, OOO), d. 9 prospekt Akademika Sakharova, Moscow 107996, Russia; Website rdif.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1117746429371; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
SME BANK (a.k.a. AKTSIONERNOE OBSHCHESTVO ROSSISKI BANK PODDERZHKI MALOGO I SREDNEGO PREDPRINIMATELSTVA; a.k.a. JSC RUSSIAN BANK FOR SMALL AND MEDIUM ENTERPRISES SUPPORT; a.k.a. JSC SME BANK; a.k.a. MSP BANK AO; f.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO ROSSISKI BANK RAZVITIYA), 79 ul. Sadovnicheskaya, Moscow 115035, Russia; SWIFT/BIC RUDV RU MM; Website mspbank.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1027739108649; All offices worldwide; for more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
SVIAZ-BANK (a.k.a. INTERREGIONAL BANK FOR SETTLEMENTS OF THE TELECOMMUNICATIONS AND POSTAL SERVICES; a.k.a. MEZHREGIONALNY KOMMERCHESKI BANK RAZVITIYA SVYAZI I INFORMATIKI (PUBLICHNOE AKTSIONERNOE OBSHCHESTVO); a.k.a. SVIAZ-BANK AKB PAO), 7 Tverskaya ul., Moscow 125375, Russia; SWIFT/BIC SVIZ RU MM; Website sviaz-bank.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1027700159288; All offices worldwide; for more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
VEB ASIA LIMITED, Suite 5808, 58/F, Two International Finance Center, 8 Finance Street Central, Hong Kong, China; Executive Order 13662 Directive Determination – Subject to Directive 1; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
VEB CAPITAL (a.k.a. LIMITED LIABILITY COMPANY VEB CAPITAL; a.k.a. LLC VEB-CAPITAL; a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU INVESTITSIONNAYA KOMPANIYA VNESHEKONOMBANKA (VEB KAPITAL); a.k.a. VEB CAPITAL LLC; a.k.a. VEB KAPITAL, OOO), d. 7 str. A ul. Mashi Poryvaevoi, Moscow 107078, Russia; Website vebcapital.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1097746831709; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
VEB ENGINEERING LLC (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU VEB INZHINIRING; a.k.a. VEB INZHINIRING, OOO), d. 9 prospekt Akademika Sakharova, Moscow 107996, Russia; Website vebeng.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1107746181674; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).
VEB LEASING OJSC (a.k.a. OJSC VEB-LEASING; a.k.a. OPEN JOINT-STOCK COMPANY VEB-LEASING; a.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO VEB-LIZING; a.k.a. VEB-LIZING, OAO), d. 10 ul. Vozdvizhenka, Moscow 125009, Russia; Website veb-leasing.ru; Executive Order 13662 Directive Determination – Subject to Directive 1; Public Registration Number 1037709024781; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] (Linked To: VNESHECONOMBANK).

and removed the following 5 people from the SDN List's Cote d'Ivoire sanctions program:

DJEDJE, Alcide Ilahiri (a.k.a. DJEDJE, Ilahiri Alcide; a.k.a. ILAHIRI, Alcide Djedje); DOB 1956 (individual) [COTED].
DJEDJE, Ilahiri Alcide (a.k.a. DJEDJE, Alcide Ilahiri; a.k.a. ILAHIRI, Alcide Djedje); DOB 1956 (individual) [COTED].
ILAHIRI, Alcide Djedje (a.k.a. DJEDJE, Alcide Ilahiri; a.k.a. DJEDJE, Ilahiri Alcide); DOB 1956 (individual) [COTED].
N'GUESSAN, Pascal Affi (a.k.a. NGUESSAN, Affi); DOB 1953; POB Bongouanou, Cote d Ivoire (individual) [COTED].
NGUESSAN, Affi (a.k.a. N'GUESSAN, Pascal Affi); DOB 1953; POB Bongouanou, Cote d Ivoire (individual) [COTED].

There was also an advisory issued about Crimean sanctions, but I'll cover that separately.

Links:

OFAC Notice

 

06.19.15
by

EU extends Crimea-related sanctions on Russia 2016

The text of the announcement:

On 19 June 2015, the Council extended the EU restrictive measures in response to the illegal annexation of Crimea and Sevastopol until 23 June 2016. The sanctions include prohibitions on:

    • imports of products originating in Crimea or Sevastopol into the EU;
    • investment in Crimea or Sevastopol, meaning that no Europeans nor EU-based companies can buy real estate or entities in Crimea, finance Crimean companies or supply related services;
    • tourism services in Crimea or Sevastopol, in particular, European cruise ships cannot call at ports in the Crimean peninsula, except in case of emergency;
    • exports of certain goods and technologies to Crimean companies or for use in Crimea in the transport, telecommunications and energy sectors and related to the prospection, exploration and production of oil, gas and mineral resources. Technical assistance, brokering, construction or engineering services related to infrastructure in these sectors must not be provided either.

As stated by the European Council on 19 March 2015, the EU continues to condemn the illegal annexation of Crimea and Sevastopol by the Russian Federation and remain committed to fully implement its non-recognition policy.

Link:

EU Announcement

 

05.29.15
by

May 22, 2015: Crimea General License 9 published

Last Friday, OFAC published General License 9 (“Exportation of Certain Services and Software Incident to Internet-Based Communications Authorized”), for the Crimea sanctions program – and a related FAQ which explains it all:

454. Does General License No. 9 authorize U.S. persons to export or reexport services or software with knowledge or reason to know that such services or software are intended for an individual or entity identified on the Sectoral Sanctions Identification List (SSI List)?

General License No. 9 authorizes the exportation or reexportation, directly or indirectly, of certain services and software to persons in the Crimea region of Ukraine, including to individuals and entities identified on the SSI List or who are otherwise subject to directives under Executive Order 13662. However, General License No. 9 does not authorize the exportation or reexportation, directly or indirectly, of services or software with knowledge or reason to know that such services or software are intended for any person whose property and interests in property are blocked. Accordingly, U.S. persons engaging in transactions pursuant to General License No. 9 should conduct due diligence to ensure that such transactions do not involve individuals or entities identified on OFAC’s List of Specially Designated Nationals and Blocked Persons or whose property and interests in property are otherwise blocked. [5-21-2015]

So, entities on the SSI list can get Internet communications services or software – but not those on the SDN list (currently only Russian National Commercial Bank),

Links:

OFAC Notice

General License 9

General License 9 FAQ

 

03.31.15
by

All together now: Expanded DFAT sanctions on Russia, Crimea, Sevastopol start

Expanded Australian sanctions were initially announced on September 1st of last year, but weren't in force until today. They include the following restricted activities:

    • the export to and import from Russia of arms and related materiel;
    • the export to Russia of specified items for use in petroleum exploration and production;
    • the export to Crimea and Sevastopol of specified items for use in the energy and minerals sector;
    • commercial dealing with certain capital financial market instruments issued by certain Russian state-owned entities; and
    • Australian investment in Crimea and Sevastopol related to infrastructure, transport, telecommunications, energy, oil, gas and minerals sectors.

For individuals and firms with existing legal obligations that run afoul of the restrictions, they can apply for authorization on the Online Sanctions Administration System (OSAS).

DFAT has also released the public consultation report on these expanded sanctions.

As for the title of the post, the notice states that the expanded sanctions “closely match” those of the EU, US and Canada. Makes the boat go faster when all the oars all pull the same direction at the same speed..

Links:

DFAT Sanctions: Crimea and Sevastopol, Russia, Ukraine

Online Sanctions Administration System

Public Consultation Report

 

03.12.15
by

March 11, 2015: We’ve got a Crimea designation! and more…

Yesterday, OFAC designated the following persons under the Ukraine-related sanctions program (related to Executive Order 13660):

ABISOV, Sergei (a.k.a. ABISOV, Sergei Vadimovich); DOB 27 Nov 1967; POB Simferopol, Crimea, Ukraine (individual) [UKRAINE-EO13660].
ARBUZOV, Serhiy (a.k.a. ARBUZOV, Sergey G.; a.k.a. ARBUZOV, Serhiy Hennadiyovych); DOB 24 Mar 1976; POB Donetsk, Ukraine; Former First Deputy Prime Minister of Ukraine (individual) [UKRAINE-EO13660].
AZAROV, Mykola Yanovych (a.k.a. AZAROV, Mykola Nikolai Yanovych; a.k.a. PAKHLO, Nikolai Yanovich); DOB 17 Dec 1947; POB Kaluga, Russia; Former Prime Minister of Ukraine (individual) [UKRAINE-EO13660].
BOHATYRIOVA, Raisa Vasylivna (a.k.a. BOGATYRIOVA, Raisa; a.k.a. BOGATYROVA, Raisa; a.k.a. BOGATYRYOVA, Raisa; a.k.a. BOHATYREVA, Raisa; a.k.a. BOHATYROVA, Raisa; a.k.a. BOHATYRYOVA, Raisa; a.k.a. BOHATYRYOVA, Rayisa); DOB 06 Jan 1953; POB Bakal, Chelyabinsk, Russia (individual) [UKRAINE-EO13660].
DUGIN, Aleksandr (a.k.a. DUGIN, Aleksandr Gelyevich; a.k.a. DUGIN, Alexander Gelyevich); DOB 07 Jan 1962 (individual) [UKRAINE-EO13660].
GUBAREVA, Ekaterina (a.k.a. GUBAREVA, Yekaterina); DOB 05 Jul 1983 (individual) [UKRAINE-EO13660].
IVAKIN, Yuriy Vladimirovich (a.k.a. IVAKIN, Yurii); DOB 13 Aug 1954; POB Perevalsk, Ukraine (individual) [UKRAINE-EO13660].
KANISHCHEV, Pavel; DOB 1986 (individual) [UKRAINE-EO13660].
KARAMAN, Aleksandr (a.k.a. CARAMAN, Aleksandru; a.k.a. KARAMAN, Alexander; a.k.a. KARAMAN, Oleksandr); DOB 26 Jul 1956; POB Republic of Mordovia, Russia (individual) [UKRAINE-EO13660].
KHODAKOVSKYY, Oleksandr Sergeyevich (a.k.a. KHODAKOVSKIY, Aleksandr; a.k.a. KHODAKOVSKY, Alexander); DOB 18 Dec 1972; POB Donetsk, Ukraine (individual) [UKRAINE-EO13660].
KOVALENKO, Andrey; DOB 30 Dec 1985 (individual) [UKRAINE-EO13660].
KOZYURA, Oleg Grigorievich (a.k.a. KOZYURA, Oleg Grigoryevich); DOB 19 Dec 1962; POB Zaporozhye, Ukraine; Head of the Office of the Federal Migration Service in the City of Sevastopol (individual) [UKRAINE-EO13660].
LYAGIN, Roman (a.k.a. LIAGIN, Roman; a.k.a. LIAHIN, Roman; a.k.a. LYAHIN, Roman); DOB 30 May 1980; POB Donetsk, Ukraine (individual) [UKRAINE-EO13660].
ZDRILIUK, Serhii Anatoliyovych (a.k.a. ZDRILIUK, Serghiei; a.k.a. ZDRILYUK, Sergei; a.k.a. ZDRILYUK, Sergey; a.k.a. ZDRYLYUK, Serhiy); DOB 23 Jun 1972; POB Vinnytsia Region, Ukraine; nationality Ukraine; citizen Russia (individual) [UKRAINE-EO13660].

and one entity:

EURASIAN YOUTH UNION, Russia 3, Bagrationovskiy Proezd, House 7, Area 20 B, Office 405, Moscow 121087, Russia; Website http://rossia3.ru; Email Address esm@rossia3.ru [UKRAINE-EO13660].

In addition, they also added one firm to the Crimean part of the sanctions program (under Executive Order 13685):

RUSSIAN NATIONAL COMMERCIAL BANK (a.k.a. RNKB OAO; a.k.a. ROSSISKI NATSIONALNY KOMMERCHESKI BANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. “RNCB”), d. 9 korp. 5 ul.Krasnoproletarskaya, Moscow 127030, Russia; SWIFT/BIC RNCO RU MM; Website http://www.rncb.ru; Email Address rncb@rncb.ru; BIK (RU) 044525607; Registration ID 1027700381290 (Russia); Tax ID No. 7701105460 (Russia); Government Gazette Number 09610705 (Russia) [UKRAINE-EO13685].

Links:

OFAC Notice

 

02.05.15
by

January 30, 2015: OFAC publishes Crimea General Licenses 6, 7 & 8

Last Friday, OFAC issues 3 new General Licenses for the Crimea part of the Ukraine-related sanctions program:

  • General License 6 (Noncommercial, Personal Remittances Authorized) permits payments to persons “normally resident in Crimea” who are not blocked (and not to entities), provided that the payment is not for the operation of a business. It also authorized US persons to carry such remittances.
  • General License 7 (Operation of Accounts Authorized) allows financial institutions to operate accounts for Crimean residents, if the funds fall under the authorizations in General License 6
  • General License 8 (Transactions Related to Telecommunications and Mail Authorized) allows transactions for communications services, with the following exceptions:

(i) The provision, sale, or lease of telecommunications equipment or technology; or

(ii) The provision, sale, or lease of capacity on telecommunications transinission facilities
(such as satellite or terrestrial network activity).

as well all mail services, as long as the mail and packages being delivered don’t otherwise run afoul of the sanctions restrictions.

Links:

OFAC Notice

General License 6

General License 7

General License 8