United Arab Emirates

Business Center 1, M Floor, The Meydan Hotel, Nad Al Sheba, Dubai, United Arab Emirates

2201205, Registration Number

Since 2023, UAE-based Black Pearl Energy Trading LLC (Black Pearl) has been a major trader of Russian crude oil, including barrels priced above the $60 price cap. Since 2023, Black Pearl has likely sold more than $2 billion worth of Russian crude oil and oil products. Black Pearl has connections with the Government of the Russian Federation, which is likely involved in its operations. In particular, Black Pearl has worked with Russia-based Aktsionernoe Obshchestvo Tsentr Ekspluatatsionnykh Uslug (OSC) to move Russian oil. The OSC is wholly owned by the Government of the Russian Federation and is involved in Russian Ministry of Energy projects both domestically in Russia and abroad. Russian national Denis Olegovich Deryushkin (Deryushkin) is a Black Pearl employee involved in Black Pearl’s Russian oil-related activities. Deryushkin is a longtime operator in the Russian energy industry, having previously been the deputy director of the Russian Energy Agency (REA), a division of the Russian Ministry of Energy. While at the REA, Deryushkin created an analytical center that focuses on research and consulting and presents to Russian Ministry of Energy leadership. Russian national Alexander Valeryevich Nemirovskiy (Nemirovskiy) is another Black Pearl employee involved in Black Pearl’s Russian crude oil deals. UAE-based Conmar Maritime DMCC (Conmar) is affiliated with Black Pearl. Conmar has operated on behalf of Black Pearl, including by providing financial services. Latvian national Aleksejs Halavins (Halavins) has been deeply involved in Black Pearl’s Russian oil trade and has been a prolific buyer of above-price cap Russian oil since 2023. Black Pearl, OSC, Deryushkin, Nemirovskiy, and Halavins are being designated pursuant to E.O. 14024 for operating or having operated in the energy sector of the Russian Federation economy and pursuant to E.O. 13662 for operating in the energy sector of the Russian Federation economy.

https://home.treasury.gov/news/press-releases/jy2777

2025-01-10

US

Executive Order 13662 of March 20, 2014 Blocking Property of Additional Persons Contributing to the Situation in Ukraine

OFAC country specific

Russia

Trade sanctions

• https://ofac.treasury.gov/faqs/topic/1576

E.O. 13662. On March 20, 2014, the President, invoking the authority of, inter alia, IEEPA, issued E.O. 13662. In E.O. 13662, the President expanded the scope of the national emergency declared in E.O. 13660 and expanded by E.O. 13661, finding that the actions and policies of the Government of the Russian Federation, including its purported annexation of Crimea and its use of force in Ukraine, continue to undermine democratic processes and institutions in Ukraine; threaten its peace, security, stability, sovereignty, and territorial integrity; and contribute to the misappropriation of its assets, and thereby constitute an unusual and extraordinary threat to the national security and foreign policy of the United States. Section 1(a) of E.O. 13662 blocks, with certain exceptions, all property and interests in property that are in the United States, that come within the United States, or that are or come within the possession or control of any United States person, of any person determined by the Secretary of the Treasury, in consultation with the Secretary of State to, among other things, operate in such sectors of the Russian Federation economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, such as financial services, energy, metals and mining, engineering, and defense and related materiel.

SSI / SDN