Eduard Benderskiy (Benderskiy), a former Spetnaz officer of the Russian Federal Security Service (FSB), which is designated under numerous OFAC sanctions authorities, current Russian businessman, and the father-in-law of Evil Corp’s leader Maksim Viktorovich Yakubets (Maksim), has been a key enabler of Evil Corp’s relationship with the Russian state. Benderskiy leveraged his status and contacts to facilitate Evil Corp’s developing relationships with officials of the Russian intelligence services. After the December 2019 sanctions and indictments against Evil Corp and Maksim, Benderskiy used his extensive influence to protect the group. While he has no official position in the Russian government, Benderskiy portrays himself as an aide to the Russian Duma. Around 2017, one of Benderskiy’s private security firms was involved in providing security for Iraq-based facilities operated by the Russian oil company Lukoil OAO. This same private security firm has been lauded by the FSB, the Russian Ministry of Foreign Affairs, the Russian Duma, and other Russian government bodies. From at least 2016, Maksim had business interactions with Aleksandr Tikhonov (Tikhonov), former commander of the FSB Special purpose Center, Russian government leaders, including OFAC-designated persons Dmitry Kozak (Kozak) and Gleb Khor, and leaders of prominent Russian banks like OFAC-designated person Herman Gref (Gref), the Chief Executive Officer of Sberbank. In 2019, Benderskiy used his connections to facilitate a business deal that included Maksim and Kozak, which they believed would earn tens of millions of dollars per month. In the same year, Benderskiy hosted a meeting with Maksim and Gref to discuss business contracts with NIK. After the December 2019 sanctions and indictments against Evil Corp and Maksim, Maksim sought out Benderskiy’s guidance. Benderskiy used his extensive influence to protect the group, including his son-in-law, both by providing senior members with security and by ensuring they were not pursued by Russian internal authorities. OFAC designated Benderskiy pursuant to E.O. 14024 for being owned or controlled, or having acted or purported to act for or on behalf of, directly or indirectly, the Government of the Russian Federation, and pursuant to E.O. 13694, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support, or goods or services in support of, Maksim, a person whose property and interests in property are blocked pursuant to E.O. 13694, as amended. Benderskiy is the general director, founder, and 100 percent owner of the Russia-based business and management consulting companies Vympel-Assistance LLC and Solar-Invest LLC. OFAC designated Vympel-Assistance LLC and Solar-Invest LLC pursuant to E.O. 14024 and E.O. 13694, as amended, for being owned or controlled, or having acted or purported to act for or on behalf of, directly or indirectly, Benderskiy, a person whose property and interests in property are blocked pursuant to E.O. 14024 and E.O. 13694, as amended.
Executive Order 13694 Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities;
Executive Order 13757 Taking Additional Steps to Address the National Emergency With Respect to Significant Malicious Cyber-Enabled Activities
On December 31, 2015, OFAC issued the Cyber-Related Sanctions Regulations, 31 CFR part 578 (80 FR 81752, December 31, 2015) (the “Regulations”) to implement Executive Order (E.O.) 13694 of April 1, 2015, “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities” (80 FR 18077, April 2, 2015), pursuant to authorities delegated to the Secretary of the Treasury in E.O. 13694. The Regulations were initially issued in abbreviated form for the purpose of providing immediate guidance to the public. OFAC is revising the Regulations to further implement E.O. 13694, as amended by E.O. 13757 of December 28, 2016, “Taking Additional Steps to Address the National Emergency With Respect to Significant Malicious Cyber-Enabled Activities” (82 FR 1, January 3, 2017), as well as certain provisions of title II of the Countering America's Adversaries Through Sanctions Act (Pub. L. 115–44, 131 Stat. 886 (codified in scattered sections of 22 U.S.C.)) (CAATSA). OFAC is amending and reissuing the Regulations as a more comprehensive set of regulations that includes additional interpretive guidance and definitions, general licenses, and other regulatory provisions that will provide further guidance to the public. Due to the number of regulatory sections being updated or added, OFAC is reissuing the Regulations in their entirety.
E.O. 13694, as Amended by E.O. 13757. On April 1, 2015, the President, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), issued E.O. 13694. In E.O. 13694, the President determined that the increasing prevalence and severity of malicious cyber-enabled activities originating from, or directed by persons located, in whole or in substantial part, outside the United States constitute an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States, and declared a national emergency to deal with that threat.
On December 28, 2016, the President issued E.O. 13757 to take additional steps to deal with the national emergency with respect to significant malicious cyber-enabled activities declared in E.O. 13694. E.O. 13757 added an Annex to E.O. 13694 and amended section 1 of E.O. 13694 by replacing section 1(a) in its entirety.
