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OFAC Sanctions Russian Elites, Business Group

The Office of Foreign Assets Control last week issued a new set of Russia sanctions, designating four members of Russia’s “financial elite” and a Russian business association. The sanctions target Petr Olegovich Aven, Mikhail Maratovich Fridman, German Borisovich Khan and Alexey Viktorovich Kuzmichev, along with the Russian Association of Employers the Russian Union of Industrialists and Entrepreneurs (RSPP), a Russian technology industry organization.

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OFAC said Aven, Fridman, Khan and Kuzmichev all serve on the Alfa Group Consortium, one of Russia’s “largest financial and investment conglomerates.” Fridman is the founder of the consortium, while the others are members of the groups’ supervisory board.

The RSPP operates various “coordinating councils,” OFAC said, including ones that “promote import substitution, technology independence, and technology development.” The RSPP also has “been involved in activities related to Russia’s responses to sanctions” imposed against the country because of its war against Ukraine.

In a new frequently asked question, OFAC clarified that it hasn’t sanctioned international investment firm LetterOne Holdings. The agency said the firm “is not owned 50 percent or more by blocked persons," including Aven, Fridman, Khan and Kuzmichev.