224 Archiepiskopou Makariou C' Avenue, Flat 41, Limassol, 3030, Cyprus
Reg. ID
375229, Registration Number
Official reason
Today, the Department is taking action against a sanctions evasion scheme connected to VLADIMIR OLEGOVICH POTANIN (Potanin), one of the wealthiest oligarchs in Russia, who formerly served as a Deputy Prime Minister for the Russian Federation. Potanin was previously designated by the Department pursuant to E.O. 14024 in December 2022. The Department is designating four Liechtenstein-based foundations, PALOMA FOUNDATION (PALOMA), SPERO FOUNDATION (SPERO), NATWIN FOUNDATION (NATWIN), and CAFAR FOUNDATION (CAFAR); as well as two Cyprus-based entities, SENTIMARE ENTERPRISES LIMITED and PICOTIN HOLDINGS LIMITED, and one UAE-based entity, SENTIMARE ME LIMITED, connected to the scheme.
Given Potanin was previously the ultimate beneficial owner of SENTIMARE ENTERPRISES LIMITED and his minor children’s current equal ownership of SENTIMARE ENTERPRISES LIMITED through four foundations (PALOMA, SPERO, CAFAR, and NATWIN), Potanin retains control of PALOMA, CAFAR, SPERO, and NATWIN. Pursuant to section 1(a)(vii) of E.O. 14024, SENTIMARE ENTERPRISES LIMITED is being designated for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, PALOMA, SPERO, CAFAR, and NATWIN, persons whose property and interests in property is blocked pursuant to E.O. 14024. SENTIMARE ENTERPRISES LIMITED was previously ultimately beneficially owned by Potanin and is currently owned equally by Potanin’s minor children through PALOMA, SPERO, NATWIN, and CAFAR.
Pursuant to section 1(a)(vii) of E.O. 14024, SENTIMARE ME LIMITED and PICOTIN HOLDINGS LIMITED are being designated for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, SENTIMARE ENTERPRISES LIMITED. They are both wholly owned by SENTIMARE ENTERPRISES LIMITED.
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.
