Case No. UKRAINE-EO13661-2014-311648-1 [Application included]

Date issued: Mar. 24 2015

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TURBOFAC Commentary (898 words)

Notes:

1) BACKGROUND

On 07/16/2014, Kalashnikov Concern (KC) was blocked pursuant to EO 13661. As described in the guidance letter, the applicant sought "guidance as to whether Izhevsky Mekhanichesky Zavod JSC ('Baikal'), a Russian arms manufacturer that deals in sporting shotguns and air rifles, would be considered a blocked entity" as a result of its "relationship with" KC. The applicant provided documents, provided to it by Baikal, "indicating that Baikal's stock is 100 percent owned by Rostec" (see PDF). However, notwithstanding this, OFAC cited information, "including KC's 2014 Product Catalog found on RWC's website, [demonstrating that] KC manufactures the Baikal line of [redacted type of firearms, and that] Baikal merged with the company formerly known as Izhmash in 2012 to create what is now called KC; and Baikal continues to be identified as part of KC." Based on that "and on...