August 15, 2024
Washington, DC (Highpoint Digest) − On August 09, 2024,
the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is taking action against 19 individuals, 14 entities, and one aircraft pursuant to Belarus-related Executive Order (E.O.) 14038. This action targets persons involved in supporting Russia’s war in Ukraine through military resource production and transshipment of goods to Russia, sanctions evasion on behalf of Belarusian defense entities, and revenue generation for Belarusian oligarchs in Alyaksandr Lukashenka’s inner circle. OFAC is concurrently designating five of these targets—three individuals and two entities—pursuant to Russia-related E.O. 14024.
Lukashenka’s support for Russia’s indefensible war against Ukraine comes at a high cost for Belarus. Lukashenka has traded his country’s autonomy and standing in the international community for his and his cronies’ own financial and political benefits. Today’s action reinforces the United States’ commitment to holding the Lukashenka regime accountable for its attacks on the Belarusian democratic movement and its flagrant exploitation of the Belarusian people.
“As Belarus marks another year under Lukashenka’s rule, the regime’s blatantly corrupt, destabilizing, and anti-democratic acts—along with its continued support for Russia’s illegal invasion of Ukraine—have only further ostracized Belarus from the global community,” said Acting Under Secretary of the Treasury for Terrorism and Financial Intelligence Bradley T. Smith. “The United States, in coordination with our allies and partners, remains committed to holding the regime and its key facilitators accountable.”
In the wake of the fraudulent August 2020 Belarusian Presidential election, Lukashenka resorted to brutal crackdowns on peaceful protesters, democratic organizations, and journalists in order to illegitimately retain power. Since then, Lukashenka’s actions have eroded Belarusian civil society and enabled Lukashenka, his family, and his inner circle to enrich themselves at the expense of Belarus’s citizens and sovereignty. The Lukashenka regime continues to support Russia’s full-scale invasion of Ukraine by hosting Russian military bases and allowing Russian forces to use Belarus as a staging point for military operations.
Today’s designations are amplified by actions undertaken by the United States’ partners in the European Union (EU)—who targeted Belarusian authorities involved in human rights abuses earlier this week—and Canada and the United Kingdom, who today also announced additional sanctions on the Lukashenka regime. Together, these actions signal the international community’s continuing solidarity with the Belarusian people in their struggle for a free, democratic, and sovereign Belarus.
The Department of State also took steps to impose visa restrictions on 19 regime officials and their affiliates for their involvement in undermining democracy in Belarus, pursuant to Presidential Proclamation 8015.
PELENG SANCTIONS EVASION NETWORK
As part of the strong ties between Russia and Belarus with respect to their technology and defense-industrial industries, Belarus provides Russia with components for satellite communication systems and optical equipment. U.S.-designated Peleng JSC (Peleng) is the leading design enterprise in Belarus’s optoelectronic industry, producing components for spacecraft, satellites, and sights with thermal imagers for military vehicles. Peleng is one of Russia’s most important industrial partners in Belarus and has partnered with Russia on ventures ranging from artillery unit complex development to airfield automated meteorological systems supply. OFAC designated Peleng on December 2, 2021 pursuant to E.O. 14038 for operating or having operated in the defense and related materiel sector of the economy of Belarus and for operating or having operated in the security sector of the economy of Belarus.
LLC Laboratory of Additive Technologies (LAT), also recently known as LLC Laser Devices and Technologies, is identified as a Belarus-based entity focused on research and development in the natural sciences; however, LAT generates its revenue by supplying components to companies, including Peleng, that produce weapons for the Russian Federation and are under U.S. and EU sanctions. For example, LAT has procured encoder disks—a component for sensors that detect motion and are used in panoramic sights for T-72s or other tanks—from a Taiwanese precision instrument maker and bypassed sanctions to move the encoder disks and payment through a third-country intermediary. Yuri Aleksandrovich Chivel (Chivel), a Belarusian national, is LAT’s Director and has signed contracts certifying that LAT intends to and has supplied components to Peleng.
OFAC is designating LAT pursuant to E.O. 14038 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of Peleng, a person whose property and interests in property are blocked pursuant to E.O. 14038. OFAC is designating Chivel pursuant to E.O. 14038 for having been a leader, official, senior executive officer, or member of the board of directors of LAT, an entity whose property and interests are blocked pursuant to E.O. 14038.
OOO Ruchservomotor (Ruchservomotor) is a Belarusian developer and manufacturer of precision coordinate systems, including high precision milling and engraving products and services. Ruchservomotor’s Director, Aliaksandr Uladzimiravich Zharski (Zharski), a Belarusian national, and its Deputy Director, Siarhei Mikalaevich Sidaruk (Sidaruk), also a Belarusian national, signed contracts agreeing to supply LAT with components. Ruchservomotor also produces components for panoramic commander’s sights for T-72 and T-90 Russian tanks, for which Peleng is the end user. By using LAT as an intermediary to ship Russian military equipment components, Ruchservomotor has attempted to obfuscate its direct sales and connection to the Russian military.
OFAC is designating Ruchservomotor pursuant to E.O. 14038 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of LAT, a person whose property and interests in property are blocked pursuant to E.O. 14038. OFAC is designating Zharski and Sidaruk pursuant to E.O. 14038 for having been leaders, officials, senior executive officers, or members of the board of directors of Ruchservomotor, an entity whose property and interests are blocked pursuant to E.O. 14038.
Belarusian manufacturers LLC AlYurTekh (AlYurTekh) and its Deputy Director, Aleksey Nikolaevich Yavorski (Yavorski), a Belarusian national; ALC Diskoms (Diskoms) and its Deputy Director, Arkady Samuilovich Dimenshtein (Dimenshtein), a Belarusian national; LLC MOT (MOT) and its Commercial Director, Viktoriya Orestovna Savruk (Savruk), a Ukrainian national; LLC Grosver Grup (Grosver Grup) and its representative, Siarhei Uladzimiravich Kastsianok (Kastsianok), a Belarusian national; and Limited Liability Company Tochnaya Mekhanika (Tochnaya Mekhanika) and its Director, Aleksandr Mikolaevich Leschanka (Leschanka), a Belarusian national, have all signed contracts committing the respective companies to supply Peleng with goods or services.
OFAC is designating AlYurTekh, Diskoms, MOT, Grosver Grup, and Tochnaya Mekhanika pursuant to E.O. 14038 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of Peleng, a person whose property and interests in property are blocked pursuant to E.O. 14038.
OFAC is designating Yavorski pursuant to E.O. 14038 for having been a leader, official, senior executive officer, or member of the board of directors of AlYurTekh, an entity whose property and interests are blocked pursuant to E.O. 14038. OFAC is designating Dimenshtein pursuant to E.O. 14038 for having been a leader, official, senior executive officer, or member of the board of directors of Diskoms, an entity whose property and interests are blocked pursuant to E.O. 14038. OFAC is designating Savruk pursuant to E.O. 14038 for having been a leader, official, senior executive officer, or member of the board of directors of MOT, an entity whose property and interests are blocked pursuant to E.O. 14038. OFAC is designating Kastsianok pursuant to E.O. 14038 for having acted or is purported to have acted for or on behalf of, directly or indirectly, Grosver Grup, an entity whose property and interests are blocked pursuant to E.O. 14038. OFAC is designating Leschanka pursuant to E.O. 14038 for having been a leader, official, senior executive officer, or member of the board of directors of Tochnaya Mekhanika, an entity whose property and interests are blocked pursuant to E.O. 14038.
CARGO AIRLINE COMPANIES
Aviakompaniya Rada LLC (Rada) and UE RubiStar (RubiStar) are two private Belarusian cargo airline companies that have long operated in the international transportation of a variety of products, including general cargo, engineering equipment, live animals, and dangerous goods.
In addition to their activities in the Belarusian transportation sector, both Rada and RubiStar have provided support to Russian defense activities. More specifically, Rada provided support to internationally designated Russian Private Military Company Wagner (Wagner Group) (designated on June 20, 2017, November 15, 2022, and January 26, 2023) by moving Wagner Group personnel and supplies to and from Africa. Additionally, on multiple occasions in 2024, RubiStar provided mission support to Russia by transporting Russian military personnel to Africa; and relatedly, at the request of a Russian company, RubiStar conducted the shipment of military helicopters to Africa. Finally, Rada has also participated in the trafficking of exotic animals between Mexico and Venezuela.
Rada is led by its Commercial Director Dmitry Olegovich Ishchenko (Ishchenko), a Russian national, and its Belarusian Director Ivan Nikolaevich Nareiko, while RubiStar is represented by its Belarusian Director, Evgeniy Ivanovich Mikholap (Mikholap).
OFAC is designating Rada, RubiStar, Ishchenko, Nareiko, and Mikholap pursuant to E.O. 14038 for operating or having operated in the transportation sector of the Belarus economy.
OFAC is also designating Rada, RubiStar, Ishchenko, Nareiko, and Mikholap pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector of the Russian Federation economy. On June 12, 2024, Treasury broadened the definition of Russia’s military-industrial base to include all persons blocked pursuant to E.O. 14024. This means that foreign financial institutions risk being sanctioned for conducting or facilitating significant transactions, or providing any service, involving any person blocked pursuant to E.O. 14024. Foreign financial institutions face sanctions risk for continuing to facilitate transactions involving Russia’s military-industrial base. Financial institutions should review OFAC’s updated sanctions advisory for practical guidance on how to identify sanctions risks and implement corresponding controls.
Aviakompaniya Belkanto LLC (Belkanto) is another Belarus-based private cargo airline company that was formed on paper in 2020, but began operating in 2022 under the leadership of former executives of Belarusian state-owned cargo airline company Transaviaexport. On December 2, 2021, OFAC designated Transaviaexport for operating or having operated in the transportation sector of the economy of Belarus and for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, the Government of Belarus (GoB). Following Transaviaexport’s designation, Belkanto took ownership of one of Transaviaexport’s planes and began leasing other aircraft from the company. Belkanto’s business is focused on many of the same areas of operation as Transaviaexport, including the transshipment of goods to Russia.
OFAC is designating Belkanto pursuant to E.O. 14038 for operating or having operated in the transportation sector of the Belarus economy.
LOGISTICS COMPANIES GENERATING REVENUE FOR LUKASHENKA ‘WALLETS’ AND RE-EXPORTING GOODS TO RUSSIA
Ruzekspeditsiya LLC (Ruzekspeditsiya) and VLATE Logistic LLC (VLATE) are two Belarus-based logistics entities involved in the management of border crossing logistics and transportation services through Belarus to Russia, including the re-export of machinery, hydrocarbons, and Western European goods to Russia. These companies form the core of a logistics network controlled by U.S.-designated Lukashenka ‘wallets’ — Belarusian oligarchs who receive preferential treatment from the GoB in exchange for providing funds to Lukashenka and other members of his inner circle; financing Lukashenka’s personal projects; and publicly supporting the regime — Aliaksandr Zaitsau (February 24, 2022), Mikalai Varabei, and Aliaksey Aleksin (both on August 9, 2021). Since the August 9, 2021 U.S. designation of these oligarchs’ logistics company, Bremino Group, Ruzekspeditsiya and VLATE have taken over many of Bremino Group’s former operations, increasing these two companies’ revenue exponentially. As a result of Ruzekspeditsiya and VLATE’s connections to Zaitsau, Varabei, and Aleksin, both companies receive privileged tax status and limited customs fees from Lukashenka.
Ruzekspeditsiya and VLATE are owned and directed by six individuals—Belarusian businessmen Oleg Romualdovich Gerasim (Gerasim), Oleg Fedorovich Barabanov (Barabanov), Dmitry Mikhailovich Zamulevich (Zamulevich), and Evgeniy Yurievich Krokhotin (Krokhotin), and Russian businessmen Vladimir Mikhailovich Arkadiev (Arkadiev) and Oleg Vladimirovich Petrov (Petrov)—who are all personally connected to Zaitsau, Varabei, and Aleksin, and represent these oligarchs’ interest in the companies.
OFAC is designating Ruzekspeditsiya, VLATE, Gerasim, Petrov, Barabanov, Zamulevich, Arkadiev, and Krokhotin pursuant to E.O. 14038 for operating or having operated in the transportation sector of the Belarus economy.
DEFENSE SECTOR ENTITIES SUPPORTING RUSSIAN WAR EFFORT
Joint Stock Company Plant Legmash (Legmash) is a Belarus-based manufacturing plant that has shifted its operations to produce artillery ammunition to supply the Belarusian and Russian armed forces. In May 2024, Lukashenka visited Legmash and alongside Legmash’s Belarusian Director, Vladislav Nikolaevich Pavlenko (Pavlenko), inspected Legmash’s new defense sector operations and commented on Legmash’s importance to the Belarusian defense-industrial sector.
OFAC is designating Legmash and Pavlenko pursuant to E.O. 14038 for operating or having operated in the defense and related materiel sector of the Belarus economy.
KB Unmanned Helicopters (UAVHeli) is a Belarusian unmanned aerial vehicle (UAV) developer and manufacturer that specializes in the production of drones for use in the security and defense sectors. Since its inception, UAVHeli has been led by Belarusian businessman Vladimir Vladimirovich Chudakov (Chudakov), who has sold UAVHeli’s products to the Belarusian and Russian defense sectors.
OFAC is designating UAVHeli and Chudakov pursuant to E.O. 14038 for operating or having operated in the defense and related materiel sector of the Belarus economy.
LUKASHENKA’S LUXURY AIRLINER
Lukashenka maintains a fleet of Government of Belarus-owned planes that he uses professionally and for his personal leisure. EW-001PB is a Boeing 767-32K(ER) owned by the Government of Belarus and used as part of the fleet of presidential aircraft. OFAC is identifying EW-001PB as property in which Lukashenka, a person whose property and interests in property are blocked pursuant to E.O. 14038, has an interest. OFAC has previously identified as blocked property several other aircraft in the presidential fleet, including EW-001PA (March 24, 2023) and EW-301PJ (August 9, 2023).
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated persons described 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, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit 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.
In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entities and individuals may expose themselves to sanctions or be subject to an enforcement action. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person.
Source: U.S. Department of the Treasury
Image Credit: U. S. Department of the Treasury
