Inclusion in the SDN list for advising sanctioned persons
In a press release about the new sanctions
, OFAC links the rise in cases of sanctions evasion, inter alia, to the activities of consultants employed by sanctioned persons. OFAC believes that sanctioned persons receive assistance in evading sanctions primarily from legal, financial and wealth management advisors as well from trust and company service providers.
For instance, Sequoia Treuhand Trust and an individual representing Sequoia Treuhand Trust (a citizen of Austria and Switzerland) are included in the SDN list "for having materially assisted, sponsored, or provided financial, material, or technological support to, or goods or services to or in support of", sanctioned persons. Specifically, OFAC believes that the persons concerned provided advisory services and wealth management services to sanctioned members of the Russian elite.
The managing director of Sequoia Treuhand Trust (a citizen of Switzerland and Liechtenstein) and a member of the board of Sequoia Treuhand Trust (a citizen of Switzerland and the UK) have also been included in the SDN list as directors and executives of a sanctioned entity, i.e., Sequoia Treuhand Trust.Intermediaries of Alisher Usmanov
OFAC has revoked General License No. 15
, which previously allowed US persons to enter into transactions with companies directly or indirectly owned by Alisher Usmanov that were not on the SDN list, even though Alisher Usmanov himself has been on the SDN list since 3 March 2022.
The revocation of this license brings many organisations and individuals connected with Alisher Usmanov within the scope of US blocking sanctions:
- Demetrios Serghides (Usmanov's personal advisor — as a person controlled by or acting on behalf of a sanctioned person);
- The Sister Trust (a Cypriot trust settled by Alisher Usmanov and his sister Gulbakhor Ismailova);
- Pomerol Capital SA (a Swiss trustee company of The Sister Trust; Demetrios Serghides is a member of the board of directors of Pomerol Capital SA).
Also added to the SDN list are certain companies owned by The Sister Trust (the Cypriot company Almenor Holdings Limited, the Cayman company Navis Marine, and others), the directors of Almenor Holdings Limited, and other companies owned by Alisher Usmanov (Windfel Properties Limited, Savoler Developments Ltd, Miramonte Investments Ltd) and their directors and corporate secretary