China

1986-02-14

Shenzhen, China; Hong Kong, China

E16512030, Passport

PRC national Ting Chen (Chen) is the managing director and owner of Shenzhen CSI. Chen was also involved in a sanctions evasion scheme in which AKM sought to acquire technology via Shenzhen CSI. Chen also owns Hong Kong-based Way Good Technology Limited (Way Good). Hong Kong-based Kekotech Equipment Limited (Kekotech) has also been used to provide goods to AKM. In addition to Shenzhen CSI, Chen is also affiliated with Kekotech. PRC national Lap Shun Lee (Lee) has represented Shenzhen CSI in many of its dealings with AKM, including schemes in which AKM sought to evade sanctions against Russia. HKIT, Shenzhen CSI, Chen, and Lee were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy. Way Good was designated pursuant to E.O. 14024 for being owned or controlled by, or having acted for or purported to act for or on behalf of, directly or indirectly, Chen. Kekotech was 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, AKM, a person whose property and interests in property are blocked pursuant to E.O. 14024.

https://home.treasury.gov/news/press-releases/jy2404

2024-06-12

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