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Case No. UKRAINE-EO13661-2014-311648-1
Michael Faucette, Esq.
Mark Barnes & Associates
1350 1 Street, NW, Suite 260
Washington, DC 20005
Dear Mr. Faucette:
This responds to your request dated July 30, 2014 as supplemented on August 19, 2014, August 20, 2014, August 21, 2014, October 15, 2014, December 12, 2014, and December 17, 2014 (collectively, the "Application"), on behalf of RWC Group, LLC (RWC) to the Office of Foreign Assets Control (OFAC), seeking 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 pursuant to the Ukraine-Related Sanctions Regulations, 31 C.F.R. Part 589 (the "Regulations"). In addition, you are seeking guidance as to whether [ ] may be sold by RWC. According to the Application, RWC imports [ ] from Baikal to...
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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...