CLOSED JOINT STOCK COMPANY SCIENTIFIC AND TECHNICAL CENTER MODUL
CJSC STC MODUL
Nationality
Russia;
Russia
Address
D.3 Ul.4-ya Vosmogo Marta, Moscow, 125167, Russia
Reg. ID
1037739183892, Registration Number;
7714009178, Tax ID No.
Official reason
The Armenia-based affiliate of Milandr, Milur Electronics LLC (Milur Electronics), was initiated for the purpose of placing orders from foreign factories, producing integrated microchips, and conducting overseas sales. Milur Electronics has been used as a Milandr front company as a means to conduct Milandr’s business with foreign partners. In fact, Milandr employees have sought to access Milur Electronics’ network themselves to conduct business. Milur Electronics was designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Milandr.
Milur SA is the Switzerland-based primary shareholder of Milur Electronics and has been utilized by employees and business associates of Milandr to coordinate financial transfers to Milur Electronics. Two Milur SA officials designated today were involved in the scheme to establish Milur Electronics, Swiss national Jacques Pasche (Pasche) and Estonian and Swiss national Holger Leng (Leng). Treasury additionally designated the General Director of both Milandr itself and Milur Electronics, Russian national Mikhail Ilyich Pavlyuk (Pavlyuk). Pavlyuk, working with Milur SA, initiated the registration process in Armenia for Milur Electronics. Furthermore, Pavlyuk has worked to transfer funds from Milur SA to Milur Electronics, as part of which he siphoned a substantial amount into his personal bank account.
Milur SA 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, Milur Electronics. Pasche and Leng were designated pursuant to E.O.14024 for being leaders, officials, senior executive officers, or members of the board of directors of Milur SA. Pavlyuk was designated pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of Milur Electronics.
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.
