United Arab Emirates; United Arab Emirates

Building 38 Industrial Area No. 1, Al Dhaid City, Sharjah, United Arab Emirates; PO Box 62105, Sharjah, United Arab Emirates

11166971, Registration Number; 501015, Registration Number

Hulm Al Sahra Electric Devices Trading (Hulm Al Sahra) is a UAE-based wholesaler of electrical appliances that has sent several shipments of electronics, machinery, and optics, including almost $190,000 of U.S.-origin, U.S. export-controlled semiconductors to Russian companies between July 2022 and November 2022. At least one of these Russian companies has been involved with Joint Stock Company Machine Building Design Bureau (KBM) in activities related to Russian defense programs. Additionally, Hulm Al Sahra and one of these Russian companies have had a business relationship since at least 2015, including in the development and manufacturing of thermoelectric air conditioners for military vehicles. Hulm Al Sahra was designated pursuant to E.O. 14024 for operating or having operated in the technology and electronics sectors of the Russian Federation economy. KBM was designated by OFAC on March 24, 2022 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, Tactical Missiles Corporation JSC, a person whose property and interests are blocked pursuant to E.O. 14024.

https://home.treasury.gov/news/press-releases/jy1402

2023-04-12

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