FL-0002.222.366-2, Registration Number;
5299007BJ0JWBN3WVQ35, Legal Entity Number
Official reason
Sequoia Treuhand Trust Reg (Sequoia Treuhand Trust) is a trust services company based in Ruggell, Liechtenstein. Sequoia Treuhand Trust’s clients include Russian elites such as Gennady Nikolayevich Timchenko (Timchenko) and his family, as well as an associate of Usmanov. Timchenko was designated in March 2014 pursuant to E.O. 13661 and again in March 2022 pursuant to E.O. 14024 alongside several family members. Timchenko has also been sanctioned by Australia, Canada, the EU, Japan, New Zealand, Switzerland, and the UK.
Sequoia Treuhand Trust was designated pursuant to E.O. 14024 for having materially assisted, sponsored, or provided financial, material, or technological support to, or goods or services to or in support of, Timchenko, a person whose property and interests in property are blocked pursuant to E.O 14024.
OFAC also designated three individuals associated with Sequoia Treuhand Trust. Liechtenstein and Switzerland national Roland Oehri (Oehri) is the managing director of Sequoia Treuhand Trust. Oehri has personally managed luxury property associated with Usmanov. Switzerland and UK national Markus Jakob Giger (Giger) is a member of the board of Sequoia Treuhand Trust. Austria and Switzerland national Alexander Ostrowsky (Ostrowsky) works as a business introducer for Sequoia Treuhand Trust.
Oehri and Giger were designated pursuant to E.O. 14024 for being or having been leaders, officials, senior executive officers, or members of the board of directors of Sequoia Treuhand Trust. Ostrowsky was designated pursuant to E.O. 14024 for having materially assisted, sponsored, or provided financial, material, or technological support to, or goods or services to or in support of, Sequoia Treuhand Trust.
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.
