Hong Kong; Hong Kong; Canada

38 Gloucester Road, 1101-4, Hong Kong, China; 23/F, Tower 2, Enterprise Square Five, 38 Wang Chiu Road, Kowloon Bay, Hong Kong, China; 18C-3107 av. des Hotels, Quebec, G1W4W5, Quebec, Canada

2815744, Company Number; 70580521, Business Registration Number; 1175952143, Enterprise Number

Orloff owns and is the director and secretary of an eponymous United Kingdom-based company, Alexandre Orloff Ltd (AO Ltd). AO Ltd, in turn, owns Hong Kong-based Zvigeni Technological Systems Limited (Zvigeni) and Dougong Trading Hong Kong Limited (Dougong) and Canada-based 9105 2829 Quebec Inc. Orloff is also the founder and CEO of UAE-based Digital Marketing Awards FZ LLC (DMA). PRC-based Shanghai Techinital Materials Co Ltd (Shanghai Techinital), a producer of components for semiconductor manufacturing equipment, has made dozens of shipments to U.S.-designated Joint Stock Company Scan (JSC Scan), including of high priority dual-use technology such as signal generators and oscilloscopes. JSC Scan designs microelectronics and has its own center for designing integrated circuits. Shanghai Techinital has open contracts to provide JSC Scan with technology, despite the latter’s designation. In 2023 alone, Zvigeni transmitted more than $1.5 million to Shanghai Techinital. Orloff and Shanghai Techinital were designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy. AO Ltd, Zvigeni, Dougong, 9105 2829 Quebec Inc, and DMA were designated 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, Orloff.

https://home.treasury.gov/news/press-releases/jy2546

2024-08-23

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