On November 14, 2022, the US Department of the Treasury’s Office of Foreign Assets Control designated 14 individuals and 28 entities pursuant to Executive Order 14024, which targets officials in the Government of the Russian Federation, persons who support these officials, or persons who operate in a key sector of Russia’s economy. The new designations include multiple members of a transnational network that procures technology for the benefit of the Russian military-industrial complex or are members of a global network that supports Suleiman Abusaidovich Kerimov or Andrey Grogoryevich Guryev, 2 key elites with links to the Kremlin. These designations were imposed just one month after the US Departments of Treasury, Commerce and State published a joint alert detailing the impact of international sanctions and export controls. Included among the new designees are Kerimov’s immediate family members and entities that they own or control. In addition to the designations, OFAC identified 8 aircraft as blocked property for their association with Emperor Aviation Ltd, a newly-designated entity that allegedly provided luxury travel for Kerimov’s immediate family members.
OFAC also issued General License 40C pursuant to the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR), 31 CFR part 587. The GL authorizes all transactions related to the provision, exportation, or reexportation of goods, technology or services involving blocked entities, including Emperor Aviation, which are listed in the Annex to GL 40C. OFAC issued GL 40C to ensure the safety of civil aviation by authorizing transactions that would otherwise be prohibited by EO 14024. Under GL 40C, transactions are only authorized if they involve aircraft registered in a jurisdiction outside of the Russia and are related to the goods, technology or services provided solely for civil aviation purposes. GL 40C effectively replaces and supersedes GL 40B, dated August 3, 2022, in its entirety.
As a result of these designations, all property and interests in property of today’s designees within the United States or within the possession or control of a US person are blocked, and US persons are generally prohibited from engaging in transactions involving the designated persons. In addition, entities owned 50 percent or more by one or more designated persons are also blocked, unless they are exempt or authorized by a general or specific license issued by OFAC.