IMPERIAL YACHTS SARL

Monaco

27, Bd Albert 1Er, Ermanno Palace Bloc A-7ETG-N01, 98000, Monaco; Moscow, Russia; PO Box 437 Kensington Chambers, 46 50 Kensington Place, St Helier, JE4 0ZE, Jersey; United Kingdom

08S04803, Registration Number

Imperial Yachts SARL (Imperial Yachts) is a yacht brokerage that offers a variety of services relating to superyachts, including their design, order, charter, and management. In addition to their head office in Monaco, Imperial Yachts maintains an office in Russia’s capital and provides yacht-related services to Russia’s elites, including those in President Putin’s inner circle. When not in use by their owners, superyachts can be offered for charter through businesses such as Imperial Yachts, generating income for the owners, who are in some cases Russia’s oligarchs. Imperial Yachts conducts business with U.S.-designated oligarchs, including through providing management services to at least one yacht linked to an OFAC-designated individual. OFAC designated Monaco-based Imperial Yachts and its Russian CEO, Evgeniy Borisovich Kochman (Kochman), pursuant to E.O. 14024 for operating or having operated in the marine sector of the Russian Federation economy. OFAC also designated Imperial Yachts 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, Kochman. Additionally, OFAC identified the largest yacht currently available for charter through Imperial Yachts, Flying Fox, as blocked property in which Imperial Yachts has an interest.

US

https://home.treasury.gov/news/press-releases/jy0802

2022-06-02

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