Throughout 2023, Rafael Anatolyevich Gazaryan (Gazaryan) worked with Mkrtychev on arms transactions involving the DPRK and Russia. Since at least April 2023 Gazaryan has acted as a point of contact for Mkrtychev’s negotiations to obtain multiple kinds of weapons and munitions for Russia from the DPRK. In May 2023, Gazaryan likely acted as an intermediary between a Russian government official and Mkrtychev. As recently as June 2023, Gazaryan worked on purchasing certain components on Mkrtychev’s behalf. At the time of Verus LLC’s 2023 designation Gazaryan was also the company’s director. During October 2023, Gazaryan coordinated with Mkrtychev on commercial proposals involving mortars and mortar shells. Gazaryan also used Russian-based Trans Kapital Limited Liability Company to facilitate the shipment and delivery of aviation components to a North Korean weapons dealer. Gazaryan is the owner of Russia-based Rafort Limited Liability Company. Rafael Anatolyevich Gazaryan is being designated, pursuant to Executive Order 13551 (E.O. 13551), for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Ashot Mkrtychev, an individual whose property and interests in property are blocked pursuant to E.O. 13551.
Trans Kapital Limited Liability Company is being designated, pursuant to E.O. 13551, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of Rafael Anatolyevich Gazaryan, an individual whose property and interests in property are blocked pursuant to E.O. 13551.
Rafort Limited Liability Company is being designated, pursuant to E.O. 13551, for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Rafael Anatolyevich Gazaryan, an individual whose property and interests in property are blocked pursuant to E.O. 13551.
• https://ofac.treasury.gov/faqs/topic/1556
460. Can U.S. persons do business with entities in North Korea?
No. Unless authorized pursuant to a general or specific license from OFAC and/or BIS, Executive Order (E.O.) 13722 prohibits new investment in North Korea by a U.S. person and the exportation or reexportation, from the United States, or by a U.S. person, of any goods, services, or technology to North Korea. E.O. 13810 (“Imposing Additional Sanctions with Respect to North Korea”) does not modify any of those prohibitions.
Official Information
On November 4, 2010, OFAC issued the North Korea Sanctions Regulations, 31 C.F.R. part 510 (the NKSR), to implement E.O. 13466 and E.O. 13551. On June 20, 2011, OFAC amended the NKSR to implement E.O. 13570. Also on June 20, 2011, pursuant to Proclamation 8271, OFAC removed parts 500 (the Foreign Assets Control Regulations) and 505 (the Transaction Control Regulations) from 31 C.F.R. chapter V. The NKSR replace the Foreign Assets Control Regulations, to the extent they pertained to North Korea.
On August 30, 2010, the President issued E.O. 13551 pursuant to, inter alia, IEEPA, the NEA, and the United Nations Participation Act (22 U.S.C. § 287c) (the UNPA), expanding the scope of the national emergency declared in E.O. 13466 and providing for the blocking of property and interests in property of certain persons with respect to North Korea.
