Treasury Takes Aim at Third-Country Sanctions Evaders and Russian Producers Supporting Russia’s Military Industrial Base

Date issued: Oct. 30 2024

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TURBOFAC Commentary (206 words)

Notes:

1) OFAC’s October 30, 2024 designations include some notable, novel designation types, in addition to many standard “backfill”-type designations in which persons are designated for “operating in” various sectors of the Russian economy as a result of goods shipments. Notable designations include:

• Thai-based “ Intracorp” for “having operated in the trust and corporate formation services sector of the Russian Federation economy” by having “facilitated the establishment of companies in Thailand for Russians and for third-country nationals wishing to do business with the Russian market”. It is not clear whether this sort of activity is in all cases sanctionable; here OFAC highlights that intracorp “administered the top Thailand-based companies sending high priority items to Russia,” including a blocked person.

• An “India-based” company that “sent hundreds of shipments of U.S.-trademarked technology, including advanced servers designed for artificial intelligence and...