On May 16, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control imposed sanctions to disrupt and expose the deepening military cooperation between Russia and the Democratic People’s Republic of Korea (“DPRK”). To this end, OFAC designated two Russian individuals and three Russia-based entities involved in illicit trade and munitions transfers, including Rafael Anatolyevich Gazaryan, who allegedly acted as a point of contact on multiple Russia-DPRK weapons and munitions deals in 2023, and Aleksey Budnev, who allegedly facilitated the shipment of military communications equipment to Russia that most likely originated in the DPRK. According to OFAC, the designees operate through networks located in Russia and evade sanctions by moving military equipment using front companies in order to support Russia’s war against Ukraine.
These designations were imposed pursuant to Executive Order 13551, for attempting to import, export or reexport arms or related materiel from the DPRK. As a result of these designations, all property and interests in property of these designees within the United States or within the possession or control of a U.S. person are blocked, and U.S. persons are generally prohibited from engaging in transactions involving the designated persons. Entities owned 50 percent or more by one or more blocked persons are also blocked.