The US Treasury is trying to stop Russians, including persons operating outside Russia, from obtaining microchips and other crucial technology used for military purposes. A raft of individuals and entities in Europe have been designated by the authorities.

This week the US government has sanctioned a transnational network procuring technology such as microchips used by Russian military forces. The actions, by the US Department of the Treasury’s Office of Foreign Assets Control, covered 14 people and 28 entities. 

The organization said in a statement that it has designated financial “facilitators, enablers and others associated with two key Kremlin-linked elites whose fortunes are intertwined with the West.”

Additionally, OFAC has identified eight aircraft as blocked property, the statement said. “The United States will continue to expose and disrupt the Kremlin’s military supply chains and deny Russia the equipment and technology it needs to wage its illegal war against Ukraine,” Secretary of the Treasury Janet L Yellen, said. 

The Treasury noted that Russia’s defense sector relies on imported microelectronics. In one case, the department designated one wrongdoer as Milandr, a Russian microelectronics company that has been described as part of the Russian military research and development structure defense technology firm.

The Armenia-based affiliate of Milandr, Milur Electronics, was set up to place orders from foreign factors and used as a Milandr front company to transact with Milandr’s business with foreign partners. Another entity mentioned in the Treasury statement is Milur SA, the Switzerland-based primary shareholder of Milur Electronics.

Two Milur SA officials designated today were involved in the scheme to establish Milur Electronics, Swiss national Jacques Pasche and Estonian and Swiss national Holger Leng. 

The Treasury also designated the general director of Milandr itself and Milur Electronics, Russian national Mikhail Ilyich Pavlyuk. Pavlyuk, working with Milur SA, initiated the registration process in Armenia for Milur Electronics. Furthermore, Pavlyuk has worked to transfer funds from Milur SA to Milur Electronics, as part of which he siphoned a substantial amount into his personal bank account.

Finally, OFAC designated Sharp Edge Engineering, a Taiwan-based front company used to purchase microelectronic components from Asian companies. Milandr employees have used a Sharp Edge account to procure equipment. 

On September 30, OFAC designated Suleiman Abusaidovich Kerimov for being or having been a leader, official, senior executive officer, or member of the board of directors of the government of the Russian Federation. OFAC had previously designated Kerimov on April 6, 2018 for being an official of the GoR. Kerimov has also been sanctioned by Australia, Canada, the EU, Japan, New Zealand, Switzerland, and the UK.

In June 2022, OFAC issued a Notification of Blocked Property to Heritage Trust, a Delaware-based entity in which Kerimov has a property interest. As of June 30, 2022, Heritage Trust held assets valued at over $1 billion. 

OFAC has also designated Kerimov’s immediate family, including his wife Firuza Nazimovna Kerimova, daughters Gulnara Suleymanovna Kerimova and Amina Suleymanovna Kerimova, and son Said Suleymanovich Kerimov for being a spouse or adult child of Kerimov. Said Kerimova has also been sanctioned by the EU, Switzerland, and the UK.

The organization also designated four France-based real estate companies belonging to Gulnara Kerimova: Service Immobiliere Antibes SAS, Service Immobiliere et Gestion SAS, VH Antibes SAS, and Villa Lexa Estates SAS. 

OFAC has designated Swiss national Laurin Katz, who serves as president of all four of Gulnara Kerimova’s France-based companies.
Additionally, Alstone Investment AG, a Switzerland-based firm formerly known as Swiru Holding AG, was designated for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Katz. 

OFAC also designated Kerimov’s nephew Nariman Gadzhievich Gadzhiev, a Russian national residing in Switzerland. Gadzhiev is a primary financial facilitator for Kerimov. OFAC also designated United Arab Emirates-based holding company Constellation Advisors.

Another network
The Treasury said another network involved Swiss national Alexander-Walter Studhalter, who was in Kerimov’s financial network and managed Kerimov’s companies. Studhalter, who has also allegedly laundered significant amounts of money on Kerimov’s behalf, has been designated by OFAC.

OFAC also designated eight entities across six countries associated with Studhalter. These include: 
MG International AG; 
Studhalter International Group AG; 
Swiss International Advisory Group AG; 
Papa Oscar Ventures GmbH; 
Eurimo Holding SA (Eurimo), a Luxembourg-based holding company;
Papa Oscar Ventures SE SL (Papa Oscar Spain), a Spain-based holding company; 
Swiss International Real Estate Portfolio AG (SwiREP), a Switzerland-based real estate firm; and
SCI AAA Properties (SCI), a France-based real estate firm. 

Studhalter’s sons, Jeremy Eric Camille Studhalter and Hugo Ange Christophe Studhalter were both designated as being or having been leaders, officials, senior executive officers, or members of the board of directors of SwissIAG. 

OFAC designated Russian businessman and investor Murat Magomedovich Aliev, a former executive at a Kerimov investment firm, who has links to Studhalter. 

OFAC also designated the following five companies associated with Aliev:
Bonum Capital Investors Corp (Bonum BVI), a British Virgin Islands-based holding company;
Limited Liability Company Bonum Management (Bonum Management) and Limited Liability Company Bonum Investments (Bonum Investments), Russia-based financial services companies; 
Limited Liability Company RB-Esteit (RB-Esteit), a Russia-based real estate firm; and
Limited Liability Company Aviakompaniya Dalnevostochnaya KSM (KSM), a Russia-based air freight company.

OFAC identified eight aircraft as blocked property in which Emperor Aviation, the operator of the luxury planes, has an interest.