New Measures Targeting Third-Country Enablers Supporting Russia’s Military-Industrial Base

Date issued: Oct. 30 2024

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TURBOFAC Commentary (255 words)

Notes:

1) The State Department's October 30, 2024 designations are generally consistent in character with prior press releases designating third-country companies for Russia-related dealings under the “operating in” designation criteria, but a few aspects of this press release are notable vis-à-vis those issue prior:

• The State Department appears, in a systematic fashion, to be designating third-country suppliers of goods to Russia as well as the Russian wholesalers and importers to which the goods were imported.

• The State Department has included details concerning the value of the goods shipped in many cases, highlight how, in some cases, relatively low-value shipments can result in designations (see e.g. GUCLU GLOBAL LOJISTIK LIMITED SIRKETI (GUCLU GLOBAL) (shipped approximately $96,000 worth of CHPL items, including electrical equipment and diodes of U.S. and E.U.-origin, to Russia-based companies), though in this case it is likely that...