21 July 2014
Practice Group(s):
International
Arbitration
International Trade
United States and European Union Ratchet Up
Russia Sanctions
On July 16, 2014, the United States ratcheted up its sanctions on Russia in connection
with escalating tensions in Eastern Ukraine. Specifically, the U.S. Department of the
Treasury, Office of Foreign Assets Control (“OFAC”) announced the imposition of
sanctions measures targeting Russian entities in the energy and financial services
sectors. In addition, OFAC added a number of Russian and Ukrainian individuals and
entities to its Specially Designated Nationals and Blocked Persons list (“SDN list”) and
the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) followed suit
by adding the same entities to its Entity List. Finally, the European Union announced the
forthcoming imposition of additional sanctions on certain Russian entities, as well as the
suspension of certain financing/lending transactions.
United States Sanctions
Sectoral Sanctions. Pursuant to Executive Order 13662 (Mar. 20, 2014), which authorized
the imposition of sanctions targeting the defense and related materiel, energy,
engineering, financial services, and metals and mining sectors of the Russian economy,
OFAC has implemented a new type of sanctions list, the Sectoral Sanctions Identification
List (“SSIL”), that prescribes certain “less than blocking” sanctions currently targeting
listed entities in the financial services and energy sectors, as well as entities 50 percent
or more owned by such listed entities (as noted below, blocking sanctions apply to
persons identified on the SDN list). While OFAC has stopped short for now of imposing
broader sanctions targeting these sectors, the sanctions measures set forth in the SSIL
are expected to dramatically curtail access to U.S. debt and, for listed banks, equity
financing. Please note that the SSIL is distinct from the SDN list and that identification on
the SSIL does not trigger any requirement to block the assets of the listed entities (unless
such entities otherwise are designated as SDNs). Rather, U.S. persons are obligated to
reject transactions or dealings prohibited by Directive 1 (Financial Services) and Directive
2 (Energy) and, to the extent required, report the rejected transactions to OFAC.
As stated in the SSIL, under Directive 1 U.S. persons, wherever located, are prohibited
from involvement in the following: “transacting in, providing financing for, or otherwise
dealing in new debt of longer than 90 days maturity or new equity of [the entities set forth
in Appendix 1], their property, or their interests in property.” Under Directive 2, as stated
in the SSIL, U.S. persons, wherever located, are prohibited from involvement in the
following: “transacting in, providing financing for, or otherwise dealing in new debt of
longer than 90 days maturity of [the entities set forth in Appendix 2], their property, or
their interests in property.” According to OFAC, the “term debt includes bonds, loans,
extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances,
discount notes or bills, or commercial paper. The term equity includes stocks, share
issuances, depositary receipts, or any other evidence of title or ownership.” Although the
Presidential Directives underlying OFAC’s implementation of the new sanctions use the
term debt/equity “for” rather than “of” “the listed entities” it is not clear whether this
distinction could have a material impact on the scope of the sanctions, particularly given
OFAC’s clarifications, as discussed below.
United States and European Union Ratchet Up Russia
Sanctions
On their face, these prohibitions appear potentially to be quite broad, but a series of
Frequently Asked Questions published by OFAC appear to clarify the scope in a more
narrow fashion. In the case of Directive 1, the prohibition extends only to “transacting in,
providing financing for, or otherwise dealing in debt with a maturity of longer than 90 days
or equity if that debt or equity is issued after on or after July 16, 2014 . . . by, on behalf of,
or for the benefit of the persons operating in Russia’s financial sector named under
Directive 1, their property, or their interests in property.” OFAC further added that the
Directive 1 prohibitions apply to “all transactions involving new debt with a maturity of
longer than 90 days or new equity; all financing in support of such new debt or new
equity; and any dealing in, including provision of services in support of, such new debt or
new equity.” In the case of Directive 2, the prohibition extends to “transacting in,
providing financing for, or otherwise dealing in new debt—issued on or after July 16,
2014—of greater than 90 days maturity by, on behalf of, or for the benefit of the persons
operating in Russia’s energy sector named under the Directive 2, their property, or their
interests in property.” OFAC further added that the Directive 2 prohibitions apply to “all
transactions involving new debt with a maturity of longer than 90 days; all financing in
support of such new debt; and any dealing in, including provision of services in support
of, such new debt.”
OFAC further clarified that:
a) the prohibitions in both directives extend to rollover of existing debt, if such
rollover results in the creation of new debt with a maturity of longer than 90 days;
b) transacting in, providing financing for, or otherwise dealing in any debt or equity
issued prior to July 16, 2104 is permissible;
c) transacting in, providing financing for, or otherwise dealing in debt instruments
with maturities of 90 days or less is permissible;
d) transacting in, providing financing for, or otherwise dealing in new equity
instruments for entities operating in the Russian energy sector identified in
Directive 2 is permissible; and
e) U.S. financial institutions may continue to maintain correspondent accounts and
process U.S. dollar-clearing transactions for the persons identified in the
directives, so long as those activities do not involve transacting in, providing
financing for, or otherwise dealing in prohibited transaction types identified by
these directives.
Finally, OFAC issued a general license authorizing transactions by U.S. persons,
wherever located, and transactions within the United States involving derivative products
whose value is linked to an underlying asset that constitutes debt or equity, as detailed
above.
SDN Designations. In addition to the sectoral sanctions detailed above, OFAC also added
the individuals and entities set forth in Appendix 3 to the SDN list pursuant to Executive
Orders 13660 (Mar. 6, 2014) and 13661 (Mar. 17, 2014). As a result, the property and
interests in property of such individuals and entities, as well as entities that are 50
percent or more owned, directly or indirectly, by such persons, that are in the United
States, that come within the United States, or that are or come within the possession or
control of any U.S. person, are blocked.
Entity List Additions. In addition to the actions taken by OFAC, BIS has added the same
eleven entities designated by OFAC as SDNs to the Entity List under the Export
Administration Regulations (“EAR”), but has identified them in the manner set forth in
Appendix 4. Generally, the Entity List consists of entities determined by BIS to present
2
United States and European Union Ratchet Up Russia
Sanctions
an unacceptable risk of diversion into programs relating to the development of weapons
of mass destruction, terrorism, or other activities contrary to U.S. national security or
foreign policy interests. As a result of the Entity List designation, BIS has imposed a
license requirement for the export, re-export or in-country transfer of items subject to the
EAR by any person to these entities, with the presumption of denial.
European Union Sanctions
During the special meeting on 16 July, the European Council agreed to expand restrictive
measures with a view to targeting individuals and entities that are materially and
financially supporting actions undermining or threatening Ukraine’s sovereignty, territorial
integrity and independence. The legal acts implementing this decision were published on
19 July. For the moment, however, no new entities or individuals have been added to the
list of entities and individuals subject to restrictive measures. The European Council has
set a deadline of the end of July by which entities and individuals, including from Russia,
should be identified and listed under the new criteria. The EU will also consider the
possibility of targeting entities and individuals who actively provide material or financial
support to the Russian decision-makers responsible for the annexation of Crimea or the
destabilisation of Eastern-Ukraine.
The European Council also agreed to ask the European Investment Bank to suspend
new lending for Russia and to seek suspension of lending to Russia by the European
Bank for Reconstruction and Development. In addition, the European Council asked the
Commission to consider suspending some of the cooperation programmes that do not
deal exclusively with cross-border cooperation and civil society.
Further, in view of the illegal annexation of Crimea and Sevastopol by Russia, the
European Commission and the European External Action Service will provide proposals
on measures restricting European investment in Crimea. The European Council expects
that international financial institutions will refrain from financing projects that explicitly or
implicitly recognise the illegal annexation.
The Foreign Affairs Ministers of the EU Member States are meeting on 22 July and it is
very likely that further decisions regarding sanctions against Russia will be taken on that
day.
In further recent developments since our last alert, on 17 July the European Parliament
passed a non binding resolution on the situation in Ukraine. It called for a collective ban
on the sale of arms to Russia and urged such implementation until the situation in
eastern Ukraine has normalised. Both the European Parliament and the European
Council warned that any further steps by Russia to destabilise Ukraine will lead to
additional and far-reaching consequences for EU-Russian relations.
On 11 July, the Council agreed, in view of the gravity of the situation in Ukraine, to add
11 new individuals to the list of persons subject to an asset freeze, a prohibition against
making funds or economic resources available and travel restrictions. The individuals,
together with the reasons for their inclusion of persons subject to restrictive measures as
described in the EU legislation (published on 12 July), are listed in Appendix 5.
It was also announced on 7 July that Liechtenstein, Norway, Iceland, Montenegro,
Albania, as well as Ukraine will ensure that their national policies conform to EU
sanctions against Russia.
3
United States and European Union Ratchet Up Russia
Sanctions
Authors:
Brussels
London
Philip Torbøl
Vanessa Edwards
philip.torbol@klgats.com
+32.(0)2.336.1903
vanessa.edwards@klgates.com
+44.(0)20.7360.8293
Moscow
Washington D.C.
William M. Reichert
Daniel Gerkin
william.reichert@klgates.com
+7.495.643.1700
daniel.gerkin@klgates.com
+1.202.778.9168
Michael O’Neil
Donald Smith
Jerome Zaucha
mike.oneil@klgates.com
+1.202. 661-6226
donald.smith@klgates.com
+1.202.778.9079
jerome.zaucha@klgates.com
+1.202.778.9013
Ian Meredith
ian.meredith@klgates.com
+44.(0)20.7360.8171
Frank Schweitzer
frank.schweitzer@klgates.com
+1.202.778.9488
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4
United States and European Union Ratchet Up Russia
Sanctions
Appendix 1
BANK FOR DEVELOPMENT AND FOREIGN ECONOMIC AFFAIRS
(VNESHECONOMBANK) STATE CORPORATION (a.k.a. BANK RAZVITIYA I
VNESHNEEKONOMICHESKOI DEYATELNOSTI (VNESHEKONOMBANK)
GOSUDARSTVENNAYA KORPORATSIYA; a.k.a. VNESHECONOMBANK; a.k.a.
"VEB"), 9 Akademika Sakharova prospekt, Moscow 107996, Russia; SWIFT/BIC BFEA
RU MM; Website http://www.veb.ru; Email Address info@veb.ru; BIK (RU) 044525060
[UKRAINE-EO13662]
BANK RAZVITIYA I VNESHNEEKONOMICHESKOI DEYATELNOSTI
(VNESHEKONOMBANK) GOSUDARSTVENNAYA KORPORATSIYA (a.k.a. BANK FOR
DEVELOPMENT AND FOREIGN ECONOMIC AFFAIRS (VNESHECONOMBANK)
STATE CORPORATION; a.k.a. VNESHECONOMBANK; a.k.a. "VEB"), 9 Akademika
Sakharova prospekt, Moscow 107996, Russia; SWIFT/BIC BFEA RU MM; Website
http://www.veb.ru; Email Address info@veb.ru; BIK (RU) 044525060 [UKRAINEEO13662]
GAZPROMBANK GAS INDUSTRY OJSC (a.k.a. GAZPROMBANK OAO; a.k.a.
GAZPROMBANK OJSC; a.k.a. GAZPROMBANK OPEN JOINT STOCK COMPANY;
a.k.a. GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. GPB,
OAO; a.k.a. GPB, OJSC), 16, Building 1, Nametkina St., Moscow 117420, Russia; 63,
Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC GAZPRUMM;
Website www.gazprombank.ru; Email Address mailbox@gazprombank.ru; Registration
ID 1027700167110; Tax ID No. 7744001497; Government Gazette Number 09807684
[UKRAINE-EO13662]
GAZPROMBANK OAO (a.k.a. GAZPROMBANK GAS INDUSTRY OJSC; a.k.a.
GAZPROMBANK OJSC; a.k.a. GAZPROMBANK OPEN JOINT STOCK COMPANY;
a.k.a. GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. GPB,
OAO; a.k.a. GPB, OJSC), 16, Building 1, Nametkina St., Moscow 117420, Russia; 63,
Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC GAZPRUMM;
Website www.gazprombank.ru; Email Address mailbox@gazprombank.ru; Registration
ID 1027700167110; Tax ID No. 7744001497; Government Gazette Number 09807684
[UKRAINE-EO13662]
GAZPROMBANK OJSC (a.k.a. GAZPROMBANK GAS INDUSTRY OJSC; a.k.a.
GAZPROMBANK OAO; a.k.a. GAZPROMBANK OPEN JOINT STOCK COMPANY;
a.k.a. GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. GPB,
OAO; a.k.a. GPB, OJSC), 16, Building 1, Nametkina St., Moscow 117420, Russia; 63,
Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC GAZPRUMM;
Website www.gazprombank.ru; Email Address mailbox@gazprombank.ru; Registration
ID 1027700167110; Tax ID No. 7744001497; Government Gazette Number 09807684
[UKRAINE-EO13662]
GAZPROMBANK OPEN JOINT STOCK COMPANY (a.k.a. GAZPROMBANK GAS
INDUSTRY OJSC; a.k.a. GAZPROMBANK OAO; a.k.a. GAZPROMBANK OJSC; a.k.a.
GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. GPB, OAO;
a.k.a. GPB, OJSC), 16, Building 1, Nametkina St., Moscow 117420, Russia; 63,
Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC GAZPRUMM;
Website www.gazprombank.ru; Email Address mailbox@gazprombank.ru; Registration
ID 1027700167110; Tax ID No. 7744001497; Government Gazette Number 09807684
[UKRAINE-EO13662]
GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO (a.k.a.
GAZPROMBANK GAS INDUSTRY OJSC; a.k.a. GAZPROMBANK OAO; a.k.a.
5
United States and European Union Ratchet Up Russia
Sanctions
GAZPROMBANK OJSC; a.k.a. GAZPROMBANK OPEN JOINT STOCK COMPANY;
a.k.a. GPB, OAO; a.k.a. GPB, OJSC), 16, Building 1, Nametkina St., Moscow 117420,
Russia; 63, Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC
GAZPRUMM; Website www.gazprombank.ru; Email Address mailbox@gazprombank.ru;
Registration ID 1027700167110; Tax ID No. 7744001497; Government Gazette Number
09807684 [UKRAINE-EO13662]
GPB, OAO (a.k.a. GAZPROMBANK GAS INDUSTRY OJSC; a.k.a. GAZPROMBANK
OAO; a.k.a. GAZPROMBANK OJSC; a.k.a. GAZPROMBANK OPEN JOINT STOCK
COMPANY; a.k.a. GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO;
a.k.a. GPB, OJSC), 16, Building 1, Nametkina St., Moscow 117420, Russia; 63,
Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC GAZPRUMM;
Website www.gazprombank.ru; Email Address mailbox@gazprombank.ru; Registration
ID 1027700167110; Tax ID No. 7744001497; Government Gazette Number 09807684
[UKRAINE-EO13662]
GPB, OJSC (a.k.a. GAZPROMBANK GAS INDUSTRY OJSC; a.k.a. GAZPROMBANK
OAO; a.k.a. GAZPROMBANK OJSC; a.k.a. GAZPROMBANK OPEN JOINT STOCK
COMPANY; a.k.a. GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO;
a.k.a. GPB, OAO), 16, Building 1, Nametkina St., Moscow 117420, Russia; 63,
Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC GAZPRUMM;
Website www.gazprombank.ru; Email Address mailbox@gazprombank.ru; Registration
ID 1027700167110; Tax ID No. 7744001497; Government Gazette Number 09807684
[UKRAINE-EO13662]
VNESHECONOMBANK (a.k.a. BANK FOR DEVELOPMENT AND FOREIGN
ECONOMIC AFFAIRS (VNESHECONOMBANK) STATE CORPORATION; a.k.a. BANK
RAZVITIYA I VNESHNEEKONOMICHESKOI DEYATELNOSTI (VNESHEKONOMBANK)
GOSUDARSTVENNAYA KORPORATSIYA; a.k.a. "VEB"), 9 Akademika Sakharova
prospekt, Moscow 107996, Russia; SWIFT/BIC BFEA RU MM; Website
http://www.veb.ru; Email Address info@veb.ru; BIK (RU) 044525060 [UKRAINEEO13662]
"VEB" (a.k.a. BANK FOR DEVELOPMENT AND FOREIGN ECONOMIC AFFAIRS
(VNESHECONOMBANK) STATE CORPORATION; a.k.a. BANK RAZVITIYA I
VNESHNEEKONOMICHESKOI DEYATELNOSTI (VNESHEKONOMBANK)
GOSUDARSTVENNAYA KORPORATSIYA; a.k.a. VNESHECONOMBANK), 9
Akademika Sakharova prospekt, Moscow 107996, Russia; SWIFT/BIC BFEA RU MM;
Website http://www.veb.ru; Email Address info@veb.ru; BIK (RU) 044525060 [UKRAINEEO13662]
6
United States and European Union Ratchet Up Russia
Sanctions
Appendix 2
FINANSOVO-INVESTITSIONNAYA KOMPANIYA NOVAFININVEST OAO (a.k.a.
NOVATEK; a.k.a. OAO NOVATEK), 2, Udaltsova Street, Moscow 119415, Russia; 22 A,
Pobedy Street, Tarko-Sale, Yamalo-Nenets Autonomous District 629580, Russia; 22a
Pobedy ul., Tarko-Sale, Purovski raion, Tyumenskaya Oblast 629850, Russia; Email
Address novatek@novatek.ru; Registration ID 1026303117642 (Russia); Government
Gazette Number 33556474 (Russia) [UKRAINE-EO13662].
NOVATEK (a.k.a. FINANSOVO-INVESTITSIONNAYA KOMPANIYA NOVAFININVEST
OAO; a.k.a. OAO NOVATEK), 2, Udaltsova Street, Moscow 119415, Russia; 22 A,
Pobedy Street, Tarko-Sale, Yamalo-Nenets Autonomous District 629580, Russia; 22a
Pobedy ul., Tarko-Sale, Purovski raion, Tyumenskaya Oblast 629850, Russia; Email
Address novatek@novatek.ru; Registration ID 1026303117642 (Russia); Government
Gazette Number 33556474 (Russia) [UKRAINE-EO13662].
OAO NOVATEK (a.k.a. FINANSOVO-INVESTITSIONNAYA KOMPANIYA
NOVAFININVEST OAO; a.k.a. NOVATEK), 2, Udaltsova Street, Moscow 119415,
Russia; 22 A, Pobedy Street, Tarko-Sale, Yamalo-Nenets Autonomous District 629580,
Russia; 22a Pobedy ul., Tarko-Sale, Purovski raion, Tyumenskaya Oblast 629850,
Russia; Email Address novatek@novatek.ru; Registration ID 1026303117642 (Russia);
Government Gazette Number 33556474 (Russia) [UKRAINE-EO13662].
OAO ROSNEFT OIL COMPANY (a.k.a. OIL COMPANY ROSNEFT; a.k.a. OJSC
ROSNEFT OIL COMPANY; a.k.a. OPEN JOINT-STOCK COMPANY ROSNEFT OIL
COMPANY; a.k.a. ROSNEFT; a.k.a. ROSNEFT OIL COMPANY), 26/1 Sofiyskaya
Embankment, Moscow 115035, Russia; Website www.rosneft.com; alt. Website
www.rosneft.ru; Email Address postman@rosneft.ru; Registration ID 1027700043502
(Russia); Tax ID No. 7706107510 (Russia); Government Gazette Number 00044428
(Russia) [UKRAINE-EO13662].
OIL COMPANY ROSNEFT (a.k.a. OAO ROSNEFT OIL COMPANY; a.k.a. OJSC
ROSNEFT OIL COMPANY; a.k.a. OPEN JOINT-STOCK COMPANY ROSNEFT OIL
COMPANY; a.k.a. ROSNEFT; a.k.a. ROSNEFT OIL COMPANY), 26/1 Sofiyskaya
Embankment, Moscow 115035, Russia; Website www.rosneft.com; alt. Website
www.rosneft.ru; Email Address postman@rosneft.ru; Registration ID 1027700043502
(Russia); Tax ID No. 7706107510 (Russia); Government Gazette Number 00044428
(Russia) [UKRAINE-EO13662].
OJSC ROSNEFT OIL COMPANY (a.k.a. OAO ROSNEFT OIL COMPANY; a.k.a. OIL
COMPANY ROSNEFT; a.k.a. OPEN JOINT-STOCK COMPANY ROSNEFT OIL
COMPANY; a.k.a. ROSNEFT; a.k.a. ROSNEFT OIL COMPANY), 26/1 Sofiyskaya
Embankment, Moscow 115035, Russia; Website www.rosneft.com; alt. Website
www.rosneft.ru; Email Address postman@rosneft.ru; Registration ID 1027700043502
(Russia); Tax ID No. 7706107510 (Russia); Government Gazette Number 00044428
(Russia) [UKRAINE-EO13662].
OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY (a.k.a. OAO ROSNEFT
OIL COMPANY; a.k.a. OIL COMPANY ROSNEFT; a.k.a. OJSC ROSNEFT OIL
COMPANY; a.k.a. ROSNEFT; a.k.a. ROSNEFT OIL COMPANY), 26/1 Sofiyskaya
Embankment, Moscow 115035, Russia; Website www.rosneft.com; alt. Website
www.rosneft.ru; Email Address postman@rosneft.ru; Registration ID 1027700043502
(Russia); Tax ID No. 7706107510 (Russia); Government Gazette Number 00044428
(Russia) [UKRAINE-EO13662].
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United States and European Union Ratchet Up Russia
Sanctions
ROSNEFT (a.k.a. OAO ROSNEFT OIL COMPANY; a.k.a. OIL COMPANY ROSNEFT;
a.k.a. OJSC ROSNEFT OIL COMPANY; a.k.a. OPEN JOINT-STOCK COMPANY
ROSNEFT OIL COMPANY; a.k.a. ROSNEFT OIL COMPANY), 26/1 Sofiyskaya
Embankment, Moscow 115035, Russia; Website www.rosneft.com; alt. Website
www.rosneft.ru; Email Address postman@rosneft.ru; Registration ID 1027700043502
(Russia); Tax ID No. 7706107510 (Russia); Government Gazette Number 00044428
(Russia) [UKRAINE-EO13662].
ROSNEFT OIL COMPANY (a.k.a. OAO ROSNEFT OIL COMPANY; a.k.a. OIL
COMPANY ROSNEFT; a.k.a. OJSC ROSNEFT OIL COMPANY; a.k.a. OPEN JOINTSTOCK COMPANY ROSNEFT OIL COMPANY; a.k.a. ROSNEFT), 26/1 Sofiyskaya
Embankment, Moscow 115035, Russia; Website www.rosneft.com; alt. Website
www.rosneft.ru; Email Address postman@rosneft.ru; Registration ID 1027700043502
(Russia); Tax ID No. 7706107510 (Russia); Government Gazette Number 00044428
(Russia) [UKRAINE-EO13662].
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United States and European Union Ratchet Up Russia
Sanctions
Appendix 3
BESEDA, Sergey (a.k.a. BESEDA, Sergei; a.k.a. BESEDA, Sergei Orestovoch); DOB
1954; Commander of the Fifth Service of the FSB; Commander of the Service for
Operational Information and International Communications of the FSB; FSB Colonel
General; Colonel-General (individual) [UKRAINE2]
BORODAI, Aleksandr (a.k.a. BORODAI, Alexander); DOB 25 Jul 1972; nationality Russia
(individual) [UKRAINE]
NEVEROV, Sergei Ivanovich (a.k.a. NEVEROV, Sergei; a.k.a. NEVEROV, Sergey); DOB
21 Dec 1961; POB Tashtagol, Russia; Deputy Chairman of the State Duma of the
Russian Federation; Member of the State Duma Committee on Housing Policy and
Housing and Communal Services (individual) [UKRAINE2]
SAVELYEV, Oleg Genrikhovich; DOB 27 Oct 1965; POB St. Petersburg, Russia; Minister
for Crimean Affairs (individual) [UKRAINE2]
SHCHEGOLEV, Igor (a.k.a. SHCHYOGOLEV, Igor Olegovich); DOB 10 Nov 1965; POB
Vinnitsa, Ukraine; alt. POB Vinnytsia, Ukraine; Aide to the President of the Russian
Federation (individual) [UKRAINE2]
DONETSK PEOPLE'S REPUBLIC, Donetsk Region, Ukraine [UKRAINE]
FEDERAL STATE UNITARY ENTERPRISE STATE RESEARCH AND PRODUCTION
ENTERPRISE BAZALT (a.k.a. FEDERAL STATE UNITARY ENTERPRISE, STATE
RESEARCH AND PRODUCTION ENTERPRISE BAZALT; a.k.a. FSUE SRPE BAZALT;
a.k.a. STATE RESEARCH AND PRODUCTION ENTERPRISE BAZALT), 32
Velyaminovskaya, Moscow 105318, Russia; Website www.bazalt.ru; Email Address
moscow@bazalt.ru [UKRAINE2]
FEODOSIYA ENTERPRISE (a.k.a. FEODOSIA OIL PRODUCTS SUPPLY CO.; a.k.a.
FEODOSIYA ENTERPRISE ON PROVIDING OIL PRODUCTS; a.k.a. FEODOSIYSKE
COMPANY FOR THE OIL; a.k.a. THEODOSIYA OIL TERMINAL), Feodosiya,
Geologicheskaya str. 2, Crimea 98107, Ukraine; Feodosia, Str. Geological 2, Crimea
98107, Ukraine [UKRAINE]
JOINT STOCK COMPANY CONCERN RADIO-ELECTRONIC TECHNOLOGIES (a.k.a.
CONCERN RADIO-ELECTRONIC TECHNOLOGIES; a.k.a. "KRET"), 20/1 Korp. 1 ul.
Goncharnaya, Moscow 109240, Russia; Website http://www.kret.com; Registration ID
1097746084666 [UKRAINE2]
JOINT STOCK COMPANY CONCERN SOZVEZDIE (a.k.a. JSC CONCERN
SOZVEZDIE), 14 Plekhanovskaya Street, Voronezh, Russia; 14 ul. Plekhanovskaya,
Voronezh, Voronezhskaya obl. 394018, Russia; Registration ID 1053600445337
[UKRAINE2]
JOINT STOCK COMPANY MILITARY-INDUSTRIAL CORPORATION NPO
MASHINOSTROYENIA (a.k.a. JOINT STOCK COMPANY MILITARY INDUSTRIAL
CONSORTIUM NPO MASHINOSTROYENIA; a.k.a. JSC MIC NPO
MASHINOSTROYENIA; a.k.a. MIC NPO MASHINOSTROYENIA JSC; a.k.a. MIC NPO
MASHINOSTROYENIYA JSC; a.k.a. MILITARY INDUSTRIAL CORPORATION NPO
MASHINOSTROENIA OAO; a.k.a. OPEN JOINT STOCK COMPANY MILITARY
INDUSTRIAL CORPORATION SCIENTIFIC AND PRODUCTION MACHINE BUILDING
ASSOCIATION; a.k.a. VOENNO-PROMYSHLENNAYA KORPORATSIYA NAUCHNOPROIZVODSTVENNOE OBEDINENIE MASHINOSTROENIYA OAO; a.k.a. VPK NPO
MASHINOSTROENIYA), 33, Gagarina St., Reutov-town, Moscow Region 143966,
Russia; 33 Gagarin Street, Reutov, Moscow Region 143966, Russia; 33 Gagarina ul.,
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United States and European Union Ratchet Up Russia
Sanctions
Reutov, Moskovskaya obl 143966, Russia; Website www.npomash.ru; Email Address
export@npomash.ru; alt. Email Address vpk@npomash.ru; Registration ID
1075012001492 (Russia); Tax ID No. 5012039795 (Russia); Government Gazette
Number 07501739 (Russia) [UKRAINE2]
JOINT-STOCK COMPANY CONCERN ALMAZ-ANTEY (a.k.a. ALMAZ-ANTEY CORP;
a.k.a. ALMAZ-ANTEY DEFENSE CORPORATION; a.k.a. ALMAZ-ANTEY JSC; f.k.a.
OTKRYTOE AKTSIONERNOE OBSHCHESTVO KONTSERN PVO ALMAZ ANTEI), 41
ul.Vereiskaya, Moscow 121471, Russia; Website almaz-antey.ru; Email Address
antey@almaz-antey.ru [UKRAINE2]
KALASHNIKOV CONCERN (a.k.a. CONCERN KALASHNIKOV; a.k.a. IZHEVSKIY
MASHINOSTROITEL'NYI ZAVOD OAO; f.k.a. IZHMASH R&D CENTER; f.k.a. JSC NPO
IZHMASH; f.k.a. NPO IZHMASH OAO; a.k.a. OJSC CONCERN KALASHNIKOV; f.k.a.
OJSC IZHMASH; f.k.a. SCIENTIFIC PRODUCTION ASSOCIATION IZHMASH JOINT
STOCK COMPANY), 3, Derjabin Pr., Izhevsk, Udmurt Republic 426006, Russia;
Registration ID 1111832003018 [UKRAINE2]
KONSTRUKTORSKOE BYURO PRIBOROSTROENIYA OTKRYTOE AKTSIONERNOE
OBSHCHESTVO (a.k.a. INSTRUMENT DESIGN BUREAU; a.k.a. JSC KBP
INSTRUMENT DESIGN BUREAU; a.k.a. KBP INSTRUMENT DESIGN BUREAU; a.k.a.
KBP INSTRUMENT DESIGN BUREAU JOINT STOCK COMPANY; a.k.a. "KBP OAO"),
59 Shcheglovskaya Zaseka ul., Tula 300001, Russia; Website www.kbptula.ru; Email
Address kbkedr@tula.net; Registration ID 1117154036911 (Russia); Government
Gazette Number 07515747 (Russia) [UKRAINE2]
LUHANSK PEOPLE'S REPUBLIC (a.k.a. LUGANSK PEOPLE'S REPUBLIC; a.k.a.
PEOPLE'S REPUBLIC OF LUHANSK), Luhansk Region, Ukraine [UKRAINE]
URALVAGONZAVOD (a.k.a. NAUCHNO-PROIZVODSTVENNAYA KORPORATSIYA
URALVAGONZAVOD OAO; a.k.a. NPK URALVAGONZAVOD; a.k.a. NPK
URALVAGONZAVOD OAO; a.k.a. OJSC RESEARCH AND PRODUCTION
CORPORATION URALVAGONZAVOD; a.k.a. RESEARCH AND PRODUCTION
CORPORATION URALVAGONZAVOD; a.k.a. RESEARCH AND PRODUCTION
CORPORATION URALVAGONZAVOD OAO; a.k.a. URALVAGONZAVOD
CORPORATION; a.k.a. "UVZ"), 28, Vostochnoye shosse, Nizhni Tagil, Sverdlovsk region
622007, Russia; 28 Vostochnoe shosse, Nizhni Tagil, Sverdlovskaya oblast 622007,
Russia; 40, Bolshaya Yakimanka Street, Moscow 119049, Russia; Vistochnoye Shosse,
28, Nizhny Tagil 622007, Russia; Website http://www.uvz.ru/; alt. Website
http://uralvagonzavod.com/; Email Address web@uvz.ru [UKRAINE2]
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Appendix 4
Donetsk People’s Republic
Feodosia Enterprise
JSC Concern Radio-Electronic Technologies
JSC Concern Sozvezdie
JSCC Almaz-Antey
Kalashnikov Concern
KBP Instrument Design Bureau
Luhansk People’s Republic
MIC NOP Mashinostroyenia
Research and Production Corporation “UralVagonZavod”
State Research and Production Enterprise “Bazalt”
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Appendix 5
1. Aleksandr Yurevich BORODAI (Александр Юрьевич Бородай) (DOB: 25.7.1972 in
Moscow) - So called ‘Prime Minister of People's Republic of Donetsk’. Responsible
for the separatist ‘governmental’ activities of the so called ‘government of the
Donetsk People's Republic’ (e.g. on 8 July stated ‘our military is conducting a special
operation against the Ukrainian “fascists”’), Signatory of the Memorandum of
Understanding on ‘Novorossiya union’.
2. Alexander KHODAKOVSKY (Александр Сергеевич Ходаковский) - So called
‘Minister of Security of People's Republic of Donetsk’. Responsible for the separatist
security activities of the so called ‘government of the Donetsk People's Republic’.
3. Alexandr Aleksandrovich KALYUSSKY, (Александр Александрович Калюсский) So called ‘de facto Deputy Prime Minister for Social Affairs of DPR’. Responsible for
the separatist ‘governmental’ activities of the so called ‘government of the Donetsk
People's Republic’.
4. Alexander KHRYAKOV - So called ‘Information and Mass Communications Minister
of DPR’. Responsible for the pro-separatist propaganda activities of the so called
‘government of the Donetsk People's Republic’.
5. Marat BASHIROV - So called ‘Prime Minister of the Council of Ministers of the
People's Republic of Luhansk, confirmed on 8 Jul’. Responsible for the separatist
‘governmental’ activities of the so called ‘government of the People's Republic of
Luhansk’.
6. Vasyl NIKITIN - So called ‘Vice Prime Minister of the Council of Ministers of the
People's Republic of Luhansk’, (used to be the so called ‘Prime Minister of the
People's Republic of Luhansk’, and former spokesman of the ‘Army of the
Southeast’). Responsible for the separatist ‘governmental’ activities of the so called
‘government of the People's Republic of Luhansk’ Responsible for the statement of
the Army of the Southeast that the Ukrainian presidential elections in the ‘People's
Republic of Luhansk’ cannot take place due to the ‘new’ status of the region.
7. Aleksey KARYAKIN (Алексей Карякин) (1979) - So called ‘Supreme Council Chair of
the People's Republic of Luhansk’. Responsible for the separatist ‘governmental’
activities of the ‘Supreme Council’, responsible for asking the Russian Federation to
recognize the independence of ‘People's Republic of Luhansk’ Signatory of the
Memorandum of Understanding on the ‘Novorossiya union’.
8. Yurij IVAKIN (Юрий Ивакин) - So called ‘Minister of Internal Affairs of the People's
Republic of Luhansk’.Responsible for the separatist ‘governmental’ activities of the so
called ‘government of the People's Republic of Luhansk’.
9. Igor PLOTNITSKY - So called ‘Defence Minister of the People's Republic of
Luhansk’. Responsible for the separatist ‘governmental’ activities of the so called
‘government of the People's Republic of Luhansk’.
10. Nikolay KOZITSYN (June 20, 1956 in Donetsk region) - Commander of Cossack
forces.Responsible for commanding separatists in Eastern Ukraine fighting against
the Ukrainian government forces.
11. Oleksiy MOZGOVY (Олексій Мозговий) - One of the leaders of armed groups in
Eastern Ukraine. Responsible for training separatists to fight against the Ukrainian
government forces.
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