The US imposed sanctions on 400 individuals and companies for helping Russia circumvent restrictions

The United States is imposing sanctions on about 400 individuals and companies for helping Russia circumvent restrictions imposed for its war against Ukraine, the US State Department announced on October 30.

US State Department spokesman Matthew Miller noted that the sanctions targeted those who contribute to Russia’s war against Ukraine by helping Russia circumvent sanctions and obtain the necessary supplies for its war machine.

“The U.S. is imposing sanctions on nearly 400 individuals and entities enabling Russia’s illegal war against Ukraine through sanctions evasion and support for its military. We will continue to use all the tools at our disposal to promote accountability for Russia’s crimes,” US State Department spokesman Matthew Miller said.

The sanctions list encompasses numerous companies from various countries, such as China, India, Malaysia, Thailand, Turkey, and the UAE. These companies were involved in the import of microelectronics and aviation components into Russia, along with Russian companies acting as importing counterparties.

Additionally, sanctions were imposed on five newly appointed deputy ministers of defense, a number of Russian companies that repair military equipment and produce technologies needed for the defense industry and Kremlin’s war efforts, and organizations related to military cooperation between Russia and Belarus.

The sanctions also targeted a company that transported equipment for the Russian Arctic LNG 2 project and a network of shipping companies from the UAE and Singapore involved in the purchase of LNG transportation vessels for Novatek.

Also, three subsidiaries of Rosatom involved in the development of digital technologies and software for its needs were sanctioned in this latest US package.

“The United States will continue to use all tools at its disposal to disrupt support for Russia’s military-industrial base and curtail the Kremlin’s ability to exploit the international financial system and generate revenue in furtherance of its war against Ukraine,” State Department’s statement said.

US concerns about Chinese exports of dual-use components to Russia

The US State Department has expressed concerns about the volume of dual-use goods being exported from China to Russia. According to the report, Chinese companies continue to supply these items to Russia, using the sanctions evasion schemes that Russia creates to procure CHPL microelectronics and machine tools for weapons production.

Imports of dual-use components from China fill critical gaps in Russia’s military production cycle, thereby enabling it to produce weapons and fuel its war efforts, according to the US.

The US State Department sanctioned several China-based firms that have supplied goods supporting Russia’s war effort. These designations target producers and exporters of CNC items critical to Russia’s military-industrial base, the report said.

List of foreign companies sanctioned for aiding Russia’s military-industrial complex

  • XH SMART TECH CHINA CO LTD (XH SMART TECH) is a PRC-based company involved in the supply of over $4.6 million worth of CHPL items such as specified electronic components (“electronic components”) to Russia-based company LIMITED LIABILITY COMPANY INTECHCARD from June 2023 to at least January 2024.
  • LIMITED LIABILITY COMPANY INTECHCARD (INTECHCARD) is a Russia-based company receiving CHPL items, such as electronic components from XH SMART TECH. INTECHCARD purportedly collaborates with eight out of ten largest banks in Russia and produces smart cards for leading fintech companies there. 
  • BEIJING DYNAMIC POWER CO. LIMITED (BEIJING DYNAMIC POWER) is a PRC-based company involved in the supply of over $2 million worth of CHPL items, such as electronic components, to Russia-based companies from January 2023 to at least January 2024.
  • OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU RTK TECHNOLOGIES is a Russia-based company receiving CHPL items, such as electronic components, from BEIJING DYNAMIC POWER.
  • YIWU VORTEX IMPORT AND EXPORT CO LIMITED is a Hong Kong-based company involved in the supply of over $32 million worth of CHPL items such as electronic components to Russia-based companies from August 2023 to at least March 2024, including the U.S.-designated, Russia-based LIMITED LIABILITY COMPANY TRADE HOUSE KYUTEK. 
  • JIANGSU CATOFISH GENERAL ELECTRIC CO LTD is a PRC-based company involved in the supply of over $1.5 million worth of CHPL items such as thermal imaging scopes to Russia-based companies from January 2023 to at least January 2024, including U.S.-designated, Russia-based LLC CITYIMPEX and KATOD. 
  • WIN KEY LIMITED is a Hong Kong-based company involved in the supply of over $5.9 million worth of CHPL items such as electronic components to Russian companies from January 2023 to at least February 2024, including U.S.-designated, Russia-based NAUCHNO PROIZVODSTVENNOE PREDPRIYATIE ITELMA. 
  • ETOP ELECTRONICS HK CO. LIMITED is a Hong Kong-based company involved in the supply of over $24 million worth of CHPL items, such as electronic components, to Russia-based companies from January 2023 to at least March 2024.
  • CLF GLOBAL LIMITED (CLF GLOBAL) is a Hong Kong-based company involved in the supply of over $22 million worth of CHPL items such as electronic components to Russia-based companies from February 2023 to at least June 2024, including U.S.-designated, Russia-based OBLTRANSTERMINAL and Russia-based LIMITED LIABILITY COMPANY EKSPRESS IMPORT. 
  • LIMITED LIABILITY COMPANY EKSPRESS IMPORT is a Russia-based electronics wholesaler receiving CHPL items, such as electronic components, from CLF Global.
  • GRANTS PROMOTION SERVICE LIMITED is a Hong Kong-based company involved in the supply of over $18 million worth of CHPL items such as electronic components to Russia-based companies from January 2023 to at least February 2024, including the U.S.-designated, Russia-based NAUCHNO PROIZVODSTVENNOE PREDPRIYATIE ITELMA. 
  • ZHUHAI RAYSHARP TECHNOLOGY CO., LTD. is a PRC-based company involved in the supply of over $1.3 million worth of CHPL items, such as security video surveillance items, to Russia-based companies from January 2023 to at least February 2024, including the U.S.-designated, Russia-based AKTSIONERNOE OBSHCHESTVO TASKOM.
  • ZHEJIANG HEADMAN MACHINERY CO., LTD. is a PRC-based company involved in the supply of over $7 million worth of CHPL items, such as CNC machine tools, to a Russia-based company from March 2023 to at least May 2024.
  • WUHAN HUAZHONG NUMERICAL CONTROL CO LTD is a PRC-based company involved in the supply of over $26 million worth of CHPL items such as CNC machine tools and ball bearings to Russia-based companies from January 2023 to at least January 2024, including U.S.-designated, Russia-based AKTSIONERNOE OBSHCHESTVO TASKOM, KAMI GROUP LIMITED LIABILITY COMPANY, and LLC MASHIMPORT.
  • JOINT STOCK COMPANY KOLOMENSKY ZAVOD (KOLOMENSKY ZAVOD) is a Russia-based manufacturing company that plays a critical role in Russia’s transport sector and military-industrial complex, as it manufactures the D500 and D49 engines ultimately used by Russian naval forces. KOLOMENSKY ZAVOD is also the receiver of foreign-origin shipments, including transmission shafts and parts for locomotive diesel engines, from PRC-based SHANGYIYUAN RESOURCES QINGDAO CO LTD. 
  • KIRILL VALERIEVICH LIPA is a Russian national and serves as the director of U.S.-designated and Russia-based TRANSMASHHOLDING JSC, the parent company of KOLOMENSKY ZAVOD. 
  • SHANGYIYUAN RESOURCES QINGDAO CO LTD (SHINE RESOURCES) is a PRC-based company that shipped over $7 million worth of items to KOLOMENSKY ZAVOD between April 2023 and March 2024, including items such as transmission shafts and parts for locomotive diesel engines. The U.S.-designated and Russia-based AO TASKOM and OBLTRANSTERMINAL served as intermediaries for some of the shipments to KOLOMENSKY ZAVOD.

Sanctions against companies that helped Russia acquire aviation components 

The Department of State also targeted in the new sanctions package companies from various countries that were involved in the procurement of U.S. and EU export-controlled aviation and electronic components for Russia.

According to the report, Moscow creates sanctions circumvention networks to procure aviation and microelectronic components in an effort to sustain its military aviation.

  • TURBOSHAFT FZE is a UAE-based company that shipped over $600,000 worth of CHPL items to Russia-based companies between January 2023 and February 2024, including to U.S.-designated and Russia-based S 7 ENGINEERING LLC. Shipments included CHPL items of U.S. origin, such as instruments and appliances for aeronautical or space navigation.
  • TURBOSHAFT DIS TICARET LIMITED SIRKETI (TURBOSHAFT AVIATION) is a Türkiye-based company that shipped over $300,000 worth of CHPL items to Russia-based companies between January 2023 and July 2023, including U.S.-designated and Russia-based LLC AVIAKOMPLANIYA POBEDA. Shipments included CHPL items of U.S. origin, such as apparatuses for the transmission and reception of audio, images, and other data.
  • TIMUR BADR is a Russian national and serves as the director of TURBOSHAFT FZE and TURBOSHAFT AVIATION. 
  • LLC SERVICE FLY BISHKEK (SERVICE FLY BISHKEK) is a Kyrgyz Republic-based company that sent over $1.2 million worth of U.S. and EU-origin CHPL (Tier 2, Tier 3, and Tier 4) items, including microelectronic and aviation components, to LIMITED LIABILITY COMPANY WAREHOUSE FORESS, a Russia-based company, between January 2024 and May 2024.
  • LIMITED LIABILITY COMPANY WAREHOUSE FORESS (WAREHOUSE FORESS) is a Russia-based aircraft repair and maintenance company that received approximately $1.2 million worth of U.S. and E.U.-origin CHPL items, including microelectronic and aviation components, from SERVICE FLY BISHKEK.
  • REKA GRUP DANISMANLIK VE TICARET LIMITED SIRKETI (REKA GRUP DANISMANLIK) is a Türkiye-based company that shipped more than $600,000 worth of U.S.-origin CHPL (Tiers 2-4) items, such as aviation components, to Russia-based companies between July 2023 and March 2024. These Russia-based companies include LIMITED LIABILITY COMPANY EURASIAN TECHNOLOGICAL ALLIANCE, LIMITED LIABILITY COMPANY AVIATION ENGINEERING AND SERVICES COMPANY, LIMITED LIABILITY COMPANY KSP TREID, which are concurrently being designated, and RAPART SERVISEZ, which is already designated by the United States.
  • The LIMITED LIABILITY COMPANY EURASIAN TECHNOLOGICAL ALLIANCE (ETA LLC), a Russia-based aircraft repair and maintenance company, received approximately $70,000 worth of shipments between May 2023 and March 2024, which included CHPL (Tiers 1, 3, and 4) items, including aviation components of U.S. origin.
  • Limited Liability Company AVIATION ENGINEERING AND SERVICES COMPANY (AESC) is a Russia-based aircraft repair and maintenance company that received shipments of U.S.-origin CHPL (Tier 2 and 4) items between July 2023 and January 2024, including aviation components from REKA GRUP DANISMANLIK.
  • The LIMITED LIABILITY COMPANY KSP TREID (KSP TREID), a wholesaler of industrial machinery based in Russia, received approximately $225,000 worth of shipments of U.S.-origin CHPL (Tier 3) items, including aviation components, from REKA GRUP DANISMANLIK in January 2024.
  • AIR LEO FZE (AIR LEO) is a UAE-based company that shipped at least $190,000 worth of shipments of CHPL items (Tiers 3–4), such as U.S.-origin aviation components, between March 2023 and March 2024. Russia-based companies, including the U.S.-designated S 7 ENGINEERING LLC and other aviation companies, received these shipments.
  • AIR LEO M AND E LTD EOOD (AIR LEO M&E) is a Bulgaria-based company that shipped CHPL items (Tiers 3-4) such as microelectronic and aviation components to Russia-based companies, which took place in November 2023. AIR LEO M&E and AIR LEO ship similar aviation components and CHPL items to the same Russia-based buyer, 4U AIRCRAFT TECHNIK, and have common leadership.
  • The LIMITED LIABILITY COMPANY 4U AIRCRAFT TECHNIK, a Russia-based aircraft repair and maintenance company, received approximately $190,000 worth of shipments, including U.S.-origin CHPL items (Tiers 3-4), from AIR LEO and AIR LEO M&E between March 2023 and March 2024.
  • 4U AIRCRAFT DESIGN AND ENGINEERING GMBH is a majority-owned Germany-based subsidiary of AIR LEO.
  • Between September 2023 and March 2024, ALTERNATE HAVACILIK SANAYI VE DIS TICARET EGITIM DANISMANLIK LIMITED SIRKETI, a company based in Turkey, shipped approximately $175,000 worth of aviation components and U.S.-origin CHPL (Tiers 3-4) items to Russia-based companies, including AESC and U.S.-designated company S 7 ENGINEERING LLC.
  • From January 2024 to March 2024, ABU RAGUEB GENERAL TRADING LLC, a UAE-based company, shipped more than $510,000 worth of U.S.-origin aviation components and CHPL Tier 3 items to U.S.-designated company S 7 ENGINEERING LLC.
  • V LINK AVIATION MANAGEMENT FZCO is a UAE-based company that shipped more than $125,000 worth of shipments that included U.S.-origin aviation components to U.S.-designated company S 7 Engineering LLC from January to March 2024.

Failure to fully enforce sanctions on Russia

The lengthy lists of third-country companies sanctioned are outrageous. On the one hand, the extent to which Russian networks have circumvented sanctions to produce weapons for the ongoing war against Ukraine is disconcerting.

On the other hand, these revelations cause outrage and incomprehension, as they reveal the extent to which companies and executives are willing to profit from the blood of Ukrainians by aiding the Putin regime in pursuing the war.

The sad outcome of these developments is that for almost three years of Russia’s full-scale war against Ukraine, despite all the sanctions and efforts of Western governments, the democratic world failed to stop the schemes of circumvention of sanctions and to enforce sanctions against Russia.

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