On December 19, OFAC and the State Department announced concerted action against Russian malign cyber- actors for their alleged role in various disruptive hacking schemes throughout the world. According to OFAC, Russia used malicious cyber actors to hack into the World Anti-Doping Agency and the Organization for the Prohibition of Chemical Weapons ("OPCW"), and other non-political organizations between 2016 and 2018. Agents of the GRU, Russia's security service, allegedly hacked into the World Anti-Doping Agency and released confidential medical information on professional athletes, reportedly in retaliation to the Agency's release of a report that exposed the Russian government's sponsorship of a doping program. For their integral role in orchestrating these and other attacks, OFAC acted pursuant to the Countering American's Adversaries Through Sanctions Act ("CAATSA") Section 224 to designate former GRU officers Aleksei Morenets and Evgenii Serebriakov. OFAC designated two additional individuals, Oleg Sotnikov and Alexey Minin for their role in a similar attack targeting the Organization for the Prohibition of Chemical Weapons.
In a concurrent action, and pursuant to CAATSA Section 231, the State Department identified twelve additional entities and individuals as part of the "defense or intelligence sectors of the Government of the Russian Federation." Pursuant to CAATSA, the President may impose secondary sanctions on any person that engages in a significant transaction with the following entities and individuals:
- Anatoliy Chepiga
- Economy Today LLC
- Federal News Agency LLC
- Elena Alekseevna Khusyaynova
- Alexander Aleksandrovich Malkevich
- Alexey Minin
- Alexander Mishkin
- Aleksei Morenets
- Nevskiy News LLC
- Evgenii Serebryakov
- Oleg Sotnikov
- USA Really
OFAC signaled a renewed focus on punishing those responsible for the March 2018 nerve gas attack on Sergei and Yulia Skripal in the United Kingdom. On December 19, OFAC targeted two persons for their individual role in carrying out the attempted assignation of the Skripals. Pursuant to its authority under CAATSA Section 224, OFAC designated GRU officers Alexander Petrov and Ruslan Boshirov.
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