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US Targets Hundreds of Entities, Including in China, Helping Russia Evade Sanctions

The U.S. this week issued a host of new Russia-related sanctions, designating nearly 100 entities as Russia-related secondary-sanctions risks and a range of other people and companies that it said are helping Russia evade sanctions. The Treasury Department sanctions specifically target a “sanctions evasion scheme” helping people in Russia and China make international payments for sensitive goods and a Kyrgyzstan bank also helping Russia evade sanctions, while new State Department sanctions target more than 150 entities and people, including in China, for supporting Russia’s military industrial base.

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The Treasury Department said it redesignated a host of already sanctioned companies operating in Russia’s financial services, energy and defense sectors under a separate authority that makes them a secondary sanctions risk. Any foreign financial institution that conducts or facilitates a “significant” transaction with one of those companies “could be subject to mandatory secondary sanctions” under the Ukraine-/Russia-related sanctions program, the agency said.

The companies are listed in three separate annexes, and include Russian banks, reinsurance companies, investment firms, oil and gas construction companies, coal transportation businesses, microelectronics companies, gunpowder producers, weapons developers, vehicle makers and more.

The Office of Foreign Assets Control also sanctioned 15 entities working to set up regional clearing platforms in both Russia and China to allow for cross-border payments for certain “sensitive goods.” The platforms help “facilitate non-cash mutual settlement for payments for so-called sanctioned goods,” and are being run under the “guidance and awareness” of both Russian and Chinese officials, OFAC said.

The Russia-based entities involved in the sanctions evasion scheme include: Herbarium Office Management LLC; Aktsionernoe Obshchestvo Atlant Torg; Limited Liability Company Sigma Partners; Aktsionernoe Obshchestvo Tranzaktsii I Raschety; Joint Stock Company Arctur; and Paylink Limited and Russian national Andrei Valeryevich Prikhodko, who is the general director of Herbarium.

The China-based entities are Anhui Hongsheng International Trade Co Ltd; Qingyuan Fo Feng Leda Supply Chain Service Co Ltd; Heilongjiang Shunsheng Economic And Trade Development Co Ltd; Qingdao Hezhi Business Service Co Ltd; Xinjiang Financial Import And Export Co Ltd; Hangzhou Xianghe Trading Co Ltd; Shaanxi Hongrun Jinhua Trading Co Ltd; Fujian Xinfuwang International Trade Co Ltd; and Jilin Province Shunda Trading Company Ltd.

OFAC also sanctioned OJSC Keremet Bank, a Kyrgyzstan bank that has coordinated with Russian officials and Promsvyazbank Public Joint Stock Company, a Russian bank sanctioned by the U.S. in 2022, to facilitate cross-border transfers on behalf of the Russian bank. The agency said the Kyrgyzstani Ministry of Finance sold a controlling stake in Keremet Bank in 2024 to a firm “strongly linked” to a Russian oligarch with ties to the Russian government, and that purchase was designed to “create a sanctions evasion hub for Russia to pay for imports and receive payment for exports.”

The State Department also targeted a range of companies and entities with ties to Russia, including China-based Haucore, a Chinese state-owned company that the agency said has supplied laser diodes to U.S.-designated Russian entities. The State Department also sanctioned Wafangdian Bearing Company, a Chinese company that it said supplied over $2.5 million worth of export controlled, common high-priority list items to Russian entities between January 2023 and at least March 2024.

The agency designated a range of other Chinese companies for supplying Russia and its military, including firms that have shipped millions worth of export controlled goods to sanctioned Russian entities. One company, Dongguan Jetland Supplier Chain Management Company, shipped more than $25 million worth of common high-priority list items, including computer numerical control machine tools, to a sanctioned Russian firm from May 2023 to at least April 2024.

New General License 122 authorizes certain wind-down transactions with some of the newly sanctioned entities, including Haucore, Wafangdian Bearing and Keremet Bank. Those transactions are authorized through 12:01 a.m. EST March 1.

New General License 123 authorizes certain debt- or equity-related transactions involving Wafangdian Bearing or any entity it owns by 50% or more. Those transactions are authorized through 12:01 a.m. EST on March 1.

Updated General License 26A, which replaces 26, authorizes certain transactions under the Russian Harmful Foreign Activities Sanctions Regulations with a list of designated companies, including ship operators, tanker owners, Russian oil companies and others. The list was updated.