Treasury Implements G7 Commitments by Prohibiting Gold Imports and Targeting Defense Industrial Base, Military and Intelligence Units, and Sanctions Evaders
FinCEN and U.S. Department of Commerce Implementing G7 Commitments by Cracking Down on Export Control Evasion
WASHINGTON – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 70 entities, many of which are critical to the Russian Federation’s defense industrial base, including State Corporation Rostec, the cornerstone of Russia’s defense, industrial, technology, and manufacturing sectors, as well as 29 Russian individuals. Today’s actions, taken pursuant to Executive Orders (E.O.s) 14024 and 14065, strike at the heart of Russia’s ability to develop and deploy weapons and technology used for Vladimir Putin’s brutal war of aggression against Ukraine.
“We once again reaffirm our commitment to working alongside our partners and allies to impose additional severe sanctions in response to Russia’s war against Ukraine,” said Secretary of the Treasury Janet L. Yellen. “Broad multilateral commitments and actions by G7 members this week further cut off the Russian Federation’s access to technology that is critical to their military. Targeting Russia’s defense industry will degrade Putin’s capabilities and further impede his war against Ukraine, which has already been plagued by poor morale, broken supply chains, and logistical failures.”
Today’s designations were taken in tandem with the U.S. Department of State, which is imposing sanctions on an additional 45 entities and 29 individuals. Included in the State Department’s action is the designation of Russian Federation military units and the re-designation of Russia’s Federal Security Service (FSB), which have been credibly implicated in human rights abuses or violations of international humanitarian law in Ukraine. The Department of State further announced steps to impose visa restrictions on officials believed to have threatened or violated Ukraine’s sovereignty, territorial integrity, or political independence, including on more than 500 Russian Federation military officers and on Russian Federation officials involved in suppressing dissent.
Concurrent with today’s sanctions actions, OFAC prohibited the importation of Russian gold into the United States, and Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a joint alert with the U.S. Department of Commerce’s Bureau of Industry and Security, advising vigilance against Russian and Belarusian export control evasion. Financial institutions and the private sector continue to play a key role in disrupting Russia’s efforts to acquire critical goods and technology to support its war-making efforts.
The Director of OFAC, in consultation with the Department of State and the Department of Commerce, determined that the prohibitions of section 1(a)(i) of E.O. 14068 shall apply to gold of Russian Federation origin, with immediate effect. As a result, the importation into the United States of gold of Russian Federation origin is prohibited, except to the extent provided by law, or unless licensed or otherwise authorized by OFAC. This determination excludes gold of Russian Federation origin that was located outside of the Russian Federation prior to today.
As announced at the G7 Summit, the United States is joined in taking action against Russian gold, the country’s biggest non-energy export, by the United Kingdom, Canada, and Japan. Even before this new prohibition, certain gold-related transactions involving the Russian Federation were sanctionable under E.O. 14024 or other Russia-related sanctions authorities. OFAC has cautioned U.S. persons to be vigilant about attempts to circumvent OFAC regulations through gold-related transactions.
State Corporation Rostec (Rostec) is a massive Russian state-owned enterprise formed to consolidate Russia’s technological, aerospace, and military-industrial expertise. Rostec is a holding company whose subsidiaries are engaged in a wide range of industries, including automotive, defense, aviation, and metals. In addition to leading Russia’s domestic defense production, Rostec also facilitates foreign trade in defense and related materiel as well as civilian and dual-purpose products. Rostec’s management umbrella includes more than 800 entities across a wide range of sectors.
Rostec was designated pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector of the Russian Federation economy. As a result, all entities owned 50 percent or more, directly or indirectly, by Rostec are blocked, even if not identified by OFAC.
Today’s action built upon previous designations of certain Rostec’s holdings pursuant to E.O. 14024 in recent months and Rostec’s previous addition to OFAC’s Sectoral Sanctions Identifications List (“SSI List”) pursuant to Directive 3 of E.O. 13662 following Russia’s 2014 invasion of Ukraine. Rostec is also sanctioned by Australia, Canada, the European Union (EU), New Zealand, Switzerland, and the United Kingdom (UK).
Today’s sanctions on Rostec subsidiary Public Joint Stock Company United Aircraft Corporation (UAC) will weaken Russia’s ability to continue its aerial assault on Ukraine. UAC and its subsidiaries and affiliated entities, described below, are critical to the Russian military’s ability to procure, maintain, and replace aircraft and related materiel.
UAC was created in 2006 by decree of recently U.S.-sanctioned Russian Federation President Vladimir Putin, to act as a holding company for Russia’s various aircraft builders. As key enterprises in Russia’s military-industrial complex, UAC and its subsidiaries develop, produce, sell, modernize, and repair military aircraft. UAC also includes the well-known military brands Sukhoi and MiG.
UAC was designated pursuant to E.O. 14024 for operating or having operated in the aerospace sector of the Russian Federation economy and for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, the Government of the Russian Federation (GoR). All entities owned 50 percent or more, directly or indirectly, by UAC are blocked, even if not identified by OFAC. UAC is also sanctioned by Canada, the EU, Japan, Switzerland, and the UK.
Tupolev Public Joint Stock Company (Tupolev), a UAC-affiliated entity, is Russia’s leading designer and producer of strategic bombers and long-range aircraft. Its bombers have been used by Russia against targets in Ukraine.
Tupolev was designated pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector and the aerospace sector of the Russian Federation economy. Tupolev is also sanctioned by Canada, New Zealand, and Switzerland.
OFAC also designated two subsidiaries through which Tupolev operates, Limited Liability Company KAPO-Avtotrans and Limited Liability Company KAPO-Zhilbitservis, pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Tupolev.
Irkut Corporation Joint Stock Company (Irkut), another UAC-affiliated entity, manufactures fighter jets for the Russian Federation’s military and does full-cycle production of a variety of military and civil aircraft.
Irkut was designated pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector and the aerospace sector of the Russian Federation economy. Irkut is also sanctioned by Canada, New Zealand, and Switzerland.
Additionally, the following Russia-based Irkut subsidiaries were designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Irkut:
All entities owned 50 percent or more, directly or indirectly, by Irkut are blocked, even if not identified by OFAC.
Public Joint Stock Company Taganrog Aviation Scientific-Technical Complex N.A.G.M. Beriev (TANTK), a subsidiary of UAC, produces a variety of aircraft, including the Be-200 amphibious aircraft and the A-50E early radar warning aircraft.
TANTK was designated pursuant to E.O. 14024 for operating or having operated in the aerospace sector of the Russian Federation economy. TANTK is also sanctioned by Canada.
Joint Stock Company Flight Research Institute N.A. M.M. Gromov (Gromov Flight Research Institute), a subsidiary of UAC, is a research and development center that includes ground and flight test complexes.
Gromov Flight Research Institute was designated pursuant to E.O. 14024 for operating or having operated in the aerospace sector of the Russian Federation economy.
Open Joint Stock Company Ilyushin Aviation Complex (Ilyushin Aviation), a UAC-affiliated company, produces civil and military aircraft, including Il-76 heavy transport aircraft used by the Russian Federation’s military for the invasion of Ukraine.
Ilyushin Aviation was designated pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector and the aerospace sector of the Russian Federation economy.
Joint Stock Company Ilyushin Finance Company (Ilyushin Finance), a UAC-affiliated financial services company, finances and delivers Russian civil aircraft to Russian and foreign airlines.
OFAC designated Ilyushin Finance pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy.
Joint Stock Company United Engine Corporation (UEC), a Rostec-affiliated holding company, produces engines in support of the GoR’s national security and defense. The motors and engines that it produces are used for military, civil, and space purposes. Specifically, UEC supplies engines for operational, tactical, transport, and training aircraft, as well as for air- and sea-based cruise missiles and space launch vehicles.
UEC was designated pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector of the Russian Federation economy. UEC was previously added to OFAC’s SSI List in 2015, pursuant to Directive 3 of E.O. 13662. UEC is also sanctioned by the EU and New Zealand.
Joint Stock Company Tekhnodinamika (Tekhnodinamika) is an aerospace and defense holding company within Rostec’s structure, and is a designer and manufacturer of aircraft equipment. Tekhnodinamika’s products are installed on virtually every Russian airliner, cargo plane, and helicopter. In addition to its civilian applications, Tekhnodinamika develops products for the Russian Federation’s military for strike and air reconnaissance missions.
Tekhnodinamika was designated pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector of the Russian Federation economy. Tekhnodinamika was previously added to OFAC’s SSI List in 2015, pursuant to Directive 3 of E.O. 13662.
In conjunction with these actions, OFAC issued General License 39, authorizing all transactions ordinarily incident and necessary to wind down any transaction involving Rostec or any entity blocked not earlier than June 28, 2022 in which Rostec owns, directly or indirectly, a 50 percent or greater interest, through 12:01 a.m. eastern daylight time, August 11, 2022. OFAC also issued General License 40 authorizing certain transactions involving certain blocked entities that are ordinarily incident and necessary to ensure the safety of civil aviation.
Joint Stock Company Concern Avtomatika (Concern Avtomatika) is a Rostec-owned holding company that develops and produces information security systems. Concern Avtomatika’s member companies and production facilities design and manufacture products tied to public security, cyber warfare, information security, and unmanned aerial vehicles. Its research and development work includes ties to military and technical cooperation.
Concern Avtomatika was designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy.
Joint Stock Company Information Security Reform (IS Reform) is a technology company within Rostec’s structure that, among other things, provides consulting on various information technology and communications-related subjects, and conducts advanced information technology training for Rostec employees. Rostec has sought to concentrate its competence in the field of information security within IS Reform.
IS Reform was designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy.
Open Joint Stock Company Russian Electronics (Ruselectronics) is a Rostec-owned holding company that unites Russia’s radio-electronic industry. Ruselectronics manufactures electronic components across more than 140 production organizations and research institutes. It is responsible for more than 50 percent of the output of electronic components in Russia.
Ruselectronics was designated pursuant to E.O. 14024 for operating or having operated in the technology and electronics sectors of the Russian Federation economy. Ruselectronics was previously added to OFAC’s SSI List in 2015, pursuant to Directive 3 of E.O. 13662, and is also sanctioned by Australia, Canada, the EU, and Switzerland.
Today, OFAC additionally designated the following Russia-based subsidiaries of Ruselectronics pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Ruselectronics. These include:
Joint Stock Company Shvabe (Shvabe), a Rostec-owned holding company, is primarily engaged in the development and serial production of optical and laser systems and complexes. Shvabe unites several dozen industrial facilities and research centers across Russia, forming the core of Russia’s optical industry. The entire cycle of creating high-technology optoelectronic and laser technology for Russia’s national defense is implemented within the Shvabe holding. Among other activities, Shvabe develops and produces optoelectronic and laser systems for the Russian Federation’s armed forces.
Shvabe was designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy. Shvabe was previously added to OFAC’s SSI List in 2015, pursuant to Directive 3 of E.O. 13662.
Today, OFAC also designated KAMAZ Publicly Traded Company (KAMAZ), Russia’s largest truck manufacturer, one of the world’s top 20 heavy duty truck producers, and a supplier of armored vehicles to Russia’s military. KAMAZ is affiliated with Rostec and is less than 50 percent owned by Rostec. In March 2022, KAMAZ trucks believed to be operated by the Russian military were seen in Belarus carrying missiles for Iskander missile systems, which are produced by U.S.-sanctioned JSC NPO High Precision Systems. These missiles were allegedly launched as part of the Russian Federation’s further invasion of Ukraine. Throughout the invasion, Russia’s KAMAZ Typhoon vehicles have also been observed carrying Russia’s military personnel throughout Ukraine.
KAMAZ was designated today pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector of the Russian Federation economy. KAMAZ is also sanctioned by Australia, Canada, the EU, New Zealand, Switzerland, and the UK.
Additionally, OFAC designated the following Russia-based subsidiaries of KAMAZ pursuant to E.O. 14024 for being owned or controlled by, or having acted for or on behalf of, directly or indirectly, KAMAZ. These include:
Of note, in an effort to reduce potential impacts to agricultural production, OFAC issued a time-limited general license, General License 41, authorizing certain transactions ordinarily incident and necessary to the manufacture, sale, and maintenance of agricultural equipment produced by Nefaz or Tutaev Motor Plant.
KAMAZ’s General Director and Chairman of the Management Board since 2002, Sergei Anatolyevich Kogogin (Kogogin), was also designated today pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector of the Russian Federation economy. Kogogin is also sanctioned by Australia, Canada, and the UK.
Additionally, OFAC designated three Russia-based companies, Zalog OOO, Limited Liability Company PFMK, and Limited Liability Company Alfa-Invest, pursuant to E.O. 14024 for being owned or controlled by, or for acting or purporting to act for or on behalf of, directly or indirectly, Kogogin. These companies are engaged in equipment rentals and leasing, furniture and paper manufacturing, and financial activities, respectively.
OFAC also designated the following entities in Rostec’s corporate structure pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Rostec:
In line with its efforts to hold the GoR accountable worldwide, OFAC maintains the authority and ability to take action against those seeking to evade sanctions. To this end, OFAC today designated three individuals and one entity that are part of a covert procurement network linked to Russia’s FSB. Alexander Aleksandrovich Kokorev (Kokorev) has sought to acquire foreign electronics for the Russian Federation’s defense industry. A former FSB officer himself, Kokorev has covertly procured U.S., Japanese, and European components for Russia’s defense-industrial use. The FSB was re-designated today pursuant to E.O. 14024 by the U.S. Department of State. Previously, OFAC designated the FSB pursuant to E.O. 13382, E.O. 13694, as amended by E.O. 13757, and section 224(a)(1)(A) of the Countering America’s Adversaries Through Sanctions Act.
In conjunction with the re-designation of FSB, OFAC issued General License 42, authorizing certain transactions with the FSB that are necessary and ordinarily incident to requesting certain licenses and authorizations for the importation, distribution, or use of certain information technology products in the Russian Federation, as well as transactions necessary and ordinarily incident to comply with rules and regulations administered by, and certain actions or investigations involving, the FSB.
Kokorev has worked together with his wife, Natalia Vasilyevna Kokoreva (Kokoreva), and covert procurement contact Dmitriy Valeryevich Afanasyev (Afanasyev). Kokorev, Kokoreva, and Afanasyev have utilized foreign countries and bank accounts as part of their illicit efforts. OFAC today additionally designated EMC Sud Limited, a legal entity registered in Hong Kong. Kokorev has used EMC Sud Limited as part of his network and for procurement for or on behalf of the FSB.
Kokorev, Kokoreva, and Afanasyev were designated pursuant to E.O. 14024 for acting or purporting to act for or on behalf of, directly or indirectly, the GoR. EMC Sud Limited was designated pursuant to E.O. 14024 for being owned or controlled by, or for acting or purporting to act for or on behalf of, directly or indirectly, Kokorev.
State Flight Testing Center Named After V.P. Chkalov (929 GLIT) is the largest testing center of the Aerospace Forces of Russia. Many new Russian aircraft, weapons, and equipment are tested and evaluated by 929 GLIT, including 4th and 5th-generation combat aircraft and air-launched weapons for combat jets, attack helicopters, and strategic bombers. Russia uses the 929 GLIT to strike Ukraine with hypersonic missiles. In April, a hypersonic missile launched at Ukraine missed its target by several hundred kilometers, hitting Russian-controlled territory. 929 GLIT also has an outpost at the Khmeimim Air Base, which is used by the Russian Federation’s military to test and deploy multiple aircraft, helicopters, and weapons systems in Syria.
929 GLIT was designated pursuant to E.O. 14024 for being a political subdivision, agency, or instrumentality of the GoR.
The Russia-based Interregional Social Organization Union of Donbas Volunteers (UDV) is officially, a 14,000-member organization largely composed of “veterans” of Russia’s unprovoked war against Ukraine and dedicated to supporting those same veterans. However, since Russia launched its full-scale invasion of Ukraine in February 2022, the UDV has taken active part in recruiting and deploying fighters for combat missions to “demilitarize and de-Nazify” Ukraine. UDV combat units are contracting with the Russian Ministry of Defense and UDV members are tasked with providing direct support for Russian military actions, including by clearing and securing territory and providing security. The UDV is also taking part in operations against Ukrainian military units. The UDV has also performed reconnaissance operations such as intelligence-gathering and scouting for Russian forces, including identifying locations for Russian military strikes against targets in Ukraine. Similar to other Russian forces fighting in Ukraine, UDV units have suffered from a lack of equipment, tactical failures, and insufficient training. The UDV was founded by Vladislav Surkov, a former Putin advisor whom the U.S. designated in March 2014.
The UDV was designated pursuant to E.O. 14024 for being responsible for or complicit in, or for having directly or indirectly engaged or attempted to engage in, activities that undermine the peace, security, political stability, or territorial integrity of the United States, its allies, or its partners, for or on behalf of, or for the benefit of, directly or indirectly, the GoR.
OFAC also designated 16 leading officials of the UDV, including the UDV’s Russia- and Dubai-based Chairman Alexander Yuryevich Boroday, the former self-proclaimed prime minister of the U.S. sanctioned so-called “Donetsk People’s Republic” (DNR) and a member of the U.S.-sanctioned State Duma of the Federal Assembly of the Russian Federation, as well as UDV Executive Director Andrei Yuryevich Pinchuk, the former head of the so-called DNR’s security apparatus.
Boroday and Pinchuk were both designated pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of the UDV. Boroday was previously designated by OFAC in July 2014 and again in March 2022 pursuant to E.O. 13662 and E.O. 14024, respectively. He is also sanctioned by Australia, Canada, the EU, Japan, Switzerland, and the UK. Pinchuk is sanctioned by Australia, Canada, the EU, New Zealand, Switzerland, and the UK.
OFAC designated the following individuals pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of the UDV:
Limited Liability Company RSB-Group (RSB-Group) is a private military company (PMC) with close ties to Russia’s intelligence services. RSB-Group hires highly trained Russian Federation Special Forces combatants, including veterans of Russia’s intelligence services. RSB-Group has provided global services for Russian companies in close coordination with the FSB, including services for military aircraft in Libya. In addition, OFAC designated RSB-Group’s General Director, Oleg Anatolyevich Krinitsyn (Krinitsyn), and another legally registered, similarly named entity under Krinitsyn’s control, Limited Liability Company Private Security Organization RSB-Group, whose listed activities include that of a private security force.
OFAC designated RSB-Group pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector of the Russian Federation economy. Krinitsyn was designated pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of RSB-Group. OFAC designated Limited Liability Company Private Security Organization RSB-Group pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Krinitsyn.
In 2014, Moscow instigated a conflict in the Donbas region of Ukraine, where Russian Federation-backed forces violently took power leading to the loss of thousands of lives. The so-called DNR and LNR were designated by OFAC pursuant to E.O. 13660 as part of the U.S. Government’s response. In February 2022, the GoR officially recognized the independence of the so-called states that Russia’s proxies established in portions of the Donbas region in violation of Ukraine’s sovereignty: the so-called DNR and LNR. In response, the United States and its partners and allies imposed a trade embargo on the area of Ukraine occupied by these so-called states in February 2022.
Those two self-proclaimed states, the DNR and LNR, are being re-designated today pursuant to E.O. 14065 for operating or having operated since the date of E.O. 14065 in the so-called DNR or LNR regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State.
Vitaliy Pavlovich Khotsenko (Khotsenko) is the newly appointed chairperson of the so-called government of the DNR. Khotsenko was previously an official in Russia’s Ministry of Industry and Trade.
Khotsenko was designated today pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of the GoR.
The following six individuals are or have been high level officials in the so-called DNR and LNR governments. They were designated today pursuant to E.O. 14065 for being or having been, since the date of E.O. 14065, leaders, officials, senior executive officers, or members of the board of directors of an entity operating in the so-called DNR or LNR regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State:
Today OFAC also designated the Advanced Research Foundation (FPI) and its director, Andrey Ivanovich Grigoryev (Grigoryev) pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector of the Russian Federation economy. OFAC designated FPI and its Director General as part of its crackdown on technology and defense companies that play an important role in the Russian Federation’s ability to wage its war against Ukraine.
FPI is a defense research organization created in 2012 under federal law by the GoR. FPI facilitates cutting edge research and development for the purposes of national defense and security, modernization of the Russian Federation’s armed forces, and creation of innovative technologies and high-tech products for military, special, and dual-use applications. FPI’s Board of Trustees contains a number of U.S.-sanctioned elites, including Aleksey Yurievich Krivoruchko, Dmitriy Olegovich Rogozin, Andrey Aleksandrovich Fursenko, and Sergey Viktorovich Chemezov, who were all previously designated pursuant to E.O. 13661. FPI collaborates on projects supported by the GRU, including development of behavior prediction tools using artificial intelligence. Additionally, FPI has worked on projects for likely end use by an elite psychological warfare unit of the GRU that is known for large-scale hacking and foreign malign influence operations.
Grigoryev is the Director General and Chairman of the Board of FPI and has headed FPI since February 2013. Grigoryev was educated at technical, military, and scientific institutes in Russia, has served in Russia’s Ministry of Defense scientific research institutions, and held leadership positions in Russia’s Ministry of Defense.
As a result of today’s action, all property and interests in property of the designated persons above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons are prohibited, unless authorized by a general or specific license issued by OFAC, or otherwise exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.
For identifying information on the individuals and entities sanctioned today, click here.
Today, the Financial Crimes Enforcement Network (FinCEN) issued a joint alert with the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), urging financial institutions to remain vigilant for possible attempts by individuals and entities to evade BIS export controls implemented in connection with Russia’s invasion of Ukraine. The joint alert provides financial institutions with an overview of BIS’s current export restrictions; a list of commodities of concern for possible export control evasion; and select transactional and behavioral red flags to assist financial institutions in identifying related suspicious transactions. This is the third alert FinCEN has issued following Russia’s full-scale invasion of Ukraine. The first alert, issued March 7, urges vigilance by financial institutions against potential Russian Federation attempts to evade sanctions. The second alert, issued March 16, highlights the importance of identifying and quickly reporting suspicious transactions involving real estate, luxury goods, and other high-value assets of sanctioned Russian Federation elites and their proxies.
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