Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is targeting a network led by Belgium-based Hans De Geetere that is involved in procuring electronics with military applications for Russian end-users. The network consists of nine entities and five individuals based in Russia, Belgium, Cyprus, Sweden, Hong Kong, and the Netherlands.
Concurrent with OFAC’s action, the U.S. Department of Justice (DOJ) unsealed two separate indictments against Hans De Geetere related to his years-long scheme to unlawfully export sensitive, military-grade technology from the United States to end users located in the People’s Republic of China (PRC) and the Russian Federation. The U.S. Department of Commerce is also concurrently adding Hans De Geetere and five entities to the Bureau of Industry and Security (BIS) Entity List. Additionally, Belgian authorities took action against De Geetere on charges related to his global illicit procurement scheme. Hans De Geetere (De Geetere) is a Belgian businessman and long-time procurement agent for Russia who serves as the director of several companies in Belgium, Cyprus, and the Netherlands. De Geetere has coordinated the procurement of electronics for Russian customers, including field programmable gate arrays (FPGA)—high priority semiconductor devices sought by Russia for its weapons programs.
De Geetere operates Belgium-based Knokke Heist Support Corporation Management (Knokke Heist), Cyprus-based Eriner Limited (Eriner), Cyprus-based The Mother Ark Ltd (The Mother Ark), and Netherlands-based European Trading Technology B.V. (European Trading Technology).
De Geetere is being designated pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector of the Russian Federation economy. Knokke Heist, Eriner, The Mother Ark, and European Trading Technology are being designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, De Geetere. In some cases, De Geetere and his network have attempted to ship electronics to Russia via transshipment points in Hong Kong, China, and Türkiye. The De Geetere-led company Eriner has repeatedly conducted business with the Hong Kongbased company M and S Trading, and coordinated electronics orders for Russia, including orders for integrated circuits of the same model as those identified in Russian-made unmanned aerial vehicles (UAV) recovered in Ukraine.
The Cyprus-based entity Lar Vorto Services Limited (Lar Vorto) is on the board of multiple De Geetere-led firms. Lar Vorto is responsible for the position of Secretary at Eriner and The Mother Ark, as well as a third firm, Ahetei Limited (Ahetei), which was led by De Geetere at the time of its establishment. Ahetei has attempted to obtain U.S.-origin accelerometers, which are dual-use devices with aerospace and military applications. The Netherlands-based company Hasa Nederland B.V. (Hasa Nederland), registered in both Belgium and the Netherlands, is a subsidiary of The Mother Ark and shares an address with European Trading Technology.
M and S Trading is being designated pursuant to E.O. 14024 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, De Geetere. Lar Vorto is being designated pursuant to E.O. 14024 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Eriner. Ahetei is being designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Lar Vorto. Hasa Nederland is being designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, The Mother Ark. In addition to the companies that he formally directs, De Geetere’s network includes the Belgium-based company European Technical Trading (ETT), founded and led by his brother, Tom De Geetere (Tom De Geetere). De Geetere has leveraged the ETT brand in attempted purchases from U.S. and European companies. In addition to his role as the founder and Director of ETT, Tom De Geetere has coordinated with his brother to procure UAV engines.
ETT is being designated pursuant to E.O. 14024 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, De Geetere. Tom De Geetere is being designated pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of ETT.
De Geetere has involved the Russian national Vladimir Kulemekov (Kulemekov) in multiple business dealings, including coordinating electronics orders for Russian entities. Kulemekov was previously employed by De Geetere and has been identified as a member of the previously designated Main Intelligence Directorate of the Russian General Staff (GRU).
Executive Order 14024 of April 15, 2021 Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation
In response to the Russian Federation’s continued use of its military-industrial base to support its aggression against Ukraine, the President has issued an Executive Order (E.O.) amending E.O. 14024 that provides the Office of Foreign Assets Control (OFAC) with new authorities to target foreign financial institutions for engaging in certain transactions. Foreign financial institutions that conduct or facilitate significant transactions or provide any service involving Russia’s military-industrial base run the risk of being sanctioned by OFAC.
The United States and partners have put in place a sanctions and export controls regime that has severely restricted Russia’s ability to import many of the items that directly support its brutal and unjustified war against Ukraine. As a result, Russia is increasingly using third countries to evade sanctions and continue its procurement of certain critical items. The United States and partners have published multiple advisories, including detailed red flags, to warn the private sector about Russian sanctions evasion in support of its war machine and to support compliance efforts. OFAC’s new targeting authorities, which are aimed at foreign financial institutions that provide services to, or engage in significant transactions relating to, Russia’s military-industrial base, come as a natural evolution of OFAC’s work to counter evasion and hold accountable those perpetuating Russia’s war against Ukraine, including financial facilitators.
OFAC is issuing this advisory to provide guidance to foreign financial institutions on the amendments to E.O. 14024, including practical guidance on how to identify sanctions risks and implement corresponding controls. For additional guidance on this E.O., please see FAQs 1146–1157.
