ARTICLE
30 October 2020

OFAC Adds Russian Entity To SDN List

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Cadwalader, Wickersham & Taft LLP

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OFAC designated the State Research Center of the Russian Federation FGUP Central Scientific Research Institute of Chemistry and Mechanics ("TsNIIKhM")
United States International Law

OFAC designated the State Research Center of the Russian Federation FGUP Central Scientific Research Institute of Chemistry and Mechanics ("TsNIIKhM") to the Specially Designated Nationals and Blocked Persons List ("SDN List") for its connection with the destructive "Triton" malware.

OFAC explained that the Triton malware manipulates safety systems at infrastructure facilities - systems that protect human life by safely executing emergency shutdowns of industrial processes. OFAC designated TsNIIKhM, pursuant to Section 224 of Countering America's Adversaries Through Sanctions Act, for knowingly undermining cybersecurity on behalf of the Government of the Russian Federation. OFAC connected the Triton malware with the ongoing involvement of the Russian government in malicious cyber-enabled activities.

As a result of the designation, all property of TsNIIKhM, and any entities owned 50 percent or more by it ("TsNIIKhM Entities") that are in the possession of U.S. persons, are blocked, and U.S. persons are generally prohibited from engaging in any dealings with the TsNIIKhM Entities. In addition, non-U.S. persons who engage in certain transactions with the TsNIIKhM Entities themselves may become the targets of U.S. sanctions.

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