On November 18, 2022, the US Department of the Treasury’s Office of Foreign Assets Control designated Russian national Dmitry Kudryakov, the leader of Solway Investment Group’s mining operations in Guatemala, and Belarusian national Iryna Litviniuk for their involvement in corrupt schemes to exploit Guatemalan mines. OFAC also designated three entities, which function as subsidiaries of Solway, for their connection to the schemes. OFAC reports that, for several years, Kudryakov and Litviniuk engaged in multiple acts of corruption, including the bribery of Guatemalan politicians, judges, and government officials, while Litviniuk additionally supported a Russian influence peddling scheme in Guatemala in which unlawful cash payments were made to public officials in order to garner support for Russian mining interests. The designations were imposed pursuant to EO 13818, which builds upon the Global Magnitsky Human Rights Accountability Act and targets persons who provide material assistance or financial support for acts of corruption.
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.
In response to these OFAC designations, Solway released a statement on November 18, 2022 emphasizing that it is a Swiss family-owned company, not a Russian company, which does not have any business relations with Russia. Solway also reiterated that it was not sanctioned by OFAC and has been fully cooperating with the US government and its investigation into the actions of two of its employees – employees who held management positions in Solway subsidiaries for many years and were immediately suspended in connection with their sanctions.