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 14024 of April 15, 2021 Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation

OFAC country specific

Russia

Blocking Property, Suspending Entry, Trade sanctions

• https://ofac.treasury.gov/faqs/1127 • https://ofac.treasury.gov/faqs/1029

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.

SDN / NS-MBS / CAPTA