International Trade Enforcement Roundup | April 2023 Update


Associate of Sanctioned Oligarch Indicted for Sanctions Evasion and Money Laundering (DOJ Action)

Those involved. Robert Wise, a U.S. attorney based in New York.

Charges and penalties. One Count of Conspiring to Commit International Money Laundering (maximum of five years in prison). What happened? On April 25, Wise, the previously unnamed New York attorney who purportedly helped Viktor Vekselberg, a designated Russian oligarch, circumvent U.S. sanctions, pleaded guilty to conspiring to commit money laundering. As discussed in our February 2023 Enforcement Roundup, Vladimir Voronchenko was the key orchestrator behind the plot to help Vekselberg, who was first sanctioned in 2018 (and redesignated in 2022, at which time his aircraft were blocked), maintain six of his U.S.-based real estate properties and thereby circumvent U.S. sanctions. Voronchenko was assisted by Wise who admitted to making tax and insurance payments on the properties, which are valued at more than $75 million.

The press release can be found here. The original press release about the indictment can be found here.

Notably. The enforcement action is a reminder that lawyers must comply with sanctions when providing legal services to sanctioned individuals. While American lawyers may contest designations in court and even counsel prohibited parties on issues related to compliance, in most other cases – including often to get paid by a prohibited party – a license from the Treasury Department’s Office of Foreign Assets Control (OFAC) must be obtained. Two People Charged for Illegally Transacting with Sergey Kurchenko, a Designated Ukrainian Oligarch (DOJ Actions) President of Metalhouse LLC Indicted for Sanctions Evasion and International Money Laundering Those involved. John Can Unsalan, president of Metalhouse LLC, a company in the steel service industry. Charges with penalties. Conspiring to Violate the International Emergency Economic Powers Act (IEEPA); Ten Counts of Violating IEEPA; One Count of Conspiring to Commit International Money Laundering; Ten Counts of International Money Laundering (maximum of 20 years in prison for each count of conviction). What happened? On April 17, the DOJ announced that it had indicted and arrested Unsalan, a Florida man, for violating U.S. sanctions by engaging with sanctioned Russian oligarch Sergey Kurchenko and two of his companies. Unsalan allegedly acted with knowledge that the transactions with Kurchenko were prohibited. Over a period of three years, Unsalan provided the sanctioned parties with over $150 million in return for steel-making equipment and raw materials. Kurchenko was sanctioned by OFAC in 2015 for his connections with former Ukrainian President Viktor Yanukovych. His two companies – Kompaniya Gaz-Alyans, OOO and ZAO Vneshtorgervis – were similarly designated in 2018 for providing material support to the so-called Donetsk People’s Republic and Luhansk People’s Republic.

The Unsalan press release can be found here.

Second Conspirator in Russia-Ukraine Sanctions Violation Case Arrested (DOJ Action) Those involved. Sergey Karpushkin, a U.S. resident and Belarusian national.

Charges with penalties. One count of Conspiring to Violate IEEPA (maximum of 20 years in prison).

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