Russia-related Designations; Publication of Russia-related Frequently Asked Question

The Office of Foreign Assets Control (OFAC) has published a new press statement to inform about new sanction measures. Specifically, the Office added four individuals and one entity to its Specially Designated Nationals and Blocked Persons List (SDN List) pursuant to Executive Order 14024 which was signed by President Joseph Biden in 2021 and subsequently amended to install sanction measures for engagements in or being responsible for „harmful foreign activities of Russia“. The parties were designated for being „prominent members of Russia’s financial elite, as well as a Russian business association“ which enable the war against Ukraine. The affected persons and entity are the following:
#### Newly sanctioned individuals
AVEN, Petr Olegovich (Cyrillic: АВЕН, Пётр Олегович) (a.k.a. AVEN, Peter Olegovich; a.k.a. AVEN, Pjotr; a.k.a. AVEN, Pyotr; a.k.a. AVENS, Pjotrs), Surrey, United Kingdom; Moscow, Russia; Latvia; DOB 16 Mar 1955; POB Moscow, Russia; nationality Russia; alt. nationality Latvia; alt. nationality Luxembourg; Gender Male; Tax ID No. 770400328495 (Russia) (individual) [RUSSIA-EO14024].
FRIDMAN, Mikhail Maratovich (Cyrillic: ФРИДМАН, Михаил Маратович), London, United Kingdom; Moscow, Russia; DOB 21 Apr 1964; POB Lviv, Ukraine; nationality Russia; alt. nationality Israel; Gender Male; Tax ID No. 1601172932 (Russia) (individual) [RUSSIA-EO14024].
KHAN, German Borisovich (Cyrillic: ХАН, Герман Борисович), Moscow, Russia; DOB 24 Oct 1961; POB Kyiv, Ukraine; nationality Russia; alt. nationality Israel; Gender Male (individual) [RUSSIA-EO14024].
KUZMICHEV, Alexey Viktorovich (a.k.a. KUZMICHEV, Alexei; a.k.a. KUZMICHYOV, Aleksey Viktorovich (Cyrillic: КУЗЬМИЧЁВ, Алексей Викторович)), France; DOB 15 Oct 1962; POB Kirov, Russia; nationality Russia; Gender Male (individual) [RUSSIA-EO14024].
#### Newly sanctioned entity
RUSSIAN ASSOCIATION OF EMPLOYERS THE RUSSIAN UNION OF INDUSTRIALISTS AND ENTREPRENEURS (a.k.a. „RSPP“), Nab. Kotelnicheskaya D.17, Moscow 109240, Russia; Organization Established Date 06 Mar 2006; Tax ID No. 7710619969 (Russia); Government Gazette Number 94430936 (Russia); Registration Number 1067746348427 (Russia) [RUSSIA-EO14024].
OFAC has also issued an accompanying statement to explain the reasoning behind this measure.
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Finally, OFAC has issued a new frequently asked question (FAQ) in relation to the new designations which reads as follows – as quoted:
FAQ 1131: Is LETTERONE HOLDINGS S.A. (LetterOne) blocked as a result of the designation of Petr Olegovich Aven, Mikhail Maratovich Fridman, German Borisovich Khan, and Alexey Viktorovich Kuzmichev?
Answer: No. OFAC has not designated LetterOne and, based on information available to OFAC, LetterOne is not owned 50 percent or more by blocked persons or otherwise considered the blocked property or interest in property of blocked persons, including Petr Olegovich Aven, Mikhail Maratovich Fridman, German Borisovich Khan, and Alexey Viktorovich Kuzmichev.