Today’s action targets a Russian sanctions evasion network led by Russia- and Cyprus-based arms dealer Igor Vladimirovich Zimenkov (Igor Zimenkov). Persons in this network (the “Zimenkov network”) have engaged in projects connected to Russian defense capabilities, including supplying a Russian company with high-technology devices after Russia launched its full-scale invasion of Ukraine on February 24, 2022. Certain members of the Zimenkov network have also supported sanctioned, state-owned Russian defense entities Rosoboroneksport OAO (Rosoboroneksport) and State Corporation Rostec (Rostec), which are key parts of Russia’s military-industrial complex. Rosoboroneksport was previously sanctioned pursuant to E.O. 14024, E.O. 13582, and E.O. 13662, and Rostec was previously sanctioned pursuant to E.O. 13662 and E.O. 14024.
Igor Zimenkov has worked closely with his son Jonatan Zimenkov and a broad network of individuals and entities to enable Russian defense sales to third-country governments. As part of these efforts, Igor and Jonatan Zimenkov both had direct correspondence with sanctioned Russian defense firms. They have additionally been involved in multiple deals for Russian cybersecurity and helicopter sales abroad and have engaged directly with Rosoboroneksport’s potential clients to enable sales of Russian defense materiel. Igor Zimenkov maintains close relationships with personnel of sanctioned Russian state-owned enterprise Rosoboroneksport and has provided information to Rostec personnel abroad. Jonatan Zimenkov has maintained Powers of Attorney for companies in the Zimenkov network on behalf of his father, Igor Zimenkov.
In addition, Igor Zimenkov has supported the Belarusian military-industrial complex by facilitating sanctioned Belarusian defense entity State Owned Foreign Trade Unitary Enterprise Belspetsvneshtechnika (BSVT)’s sales efforts in Latin America. BSVT was previously designated pursuant to Belarus-related E.O. 14038 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, the Government of Belarus, as well as for operating or having operated in the defense and related materiel sector of the Belarus economy.
Today, Igor Zimenkov was designated pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector of the Russian Federation economy. Jonatan Zimenkov was also 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, Igor Zimenkov, and for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Rosoboroneksport, a person whose property and interests in property were previously blocked pursuant to E.O. 14024.
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.
