The United States Department of Treasury stated on December 12 that last week, G7 Leaders reaffirmed their support for an independent, democratic Ukraine within is internationally recognized borders.  “Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), is implementing the commitments made by G7 Leaders by taking action against third-country actors who materially support Russia’s war; targeting Russian military procurement networks and those who help Russia acquire machine tools, equipment, and key inputs; and further curtailing Russia’s use of the international financial system to further its war in Ukraine,” says a statement.   

The Department of State is reportedly imposing sanctions on over 100 entities and individuals, including those engaged in sanctions evasion in numerous third countries, complicit in furthering Russia’s ability to wage its war against Ukraine, and responsible for bolstering Russia’s future energy production and export capacity.

Treasury reportedly continues taking action to identify and disrupt third-country individuals, entities, and networks that facilitate, arrange, and enable the transfer of key technology, equipment, and inputs to Russian military-industrial base end-users.  Many of these items have been identified by the Department of Commerce’s Bureau of Industry and Security, alongside the European Union, Japan, and the United Kingdom, as “common high priority items” because Russia seeks to procure them for its weapons programs.

Thus, sanctions were imposed on Tajikistan-based Jamaiyati Doroi Masuliyati Mahdudi Kafolati Komil (Kafolati Komil LLC).  The company was reportedly sanctioned for sending foreign-made aviation parts to Russia via the United Arab Emirates.

Kafolati Komil LLC was designated pursuant to E.O. 14024 for operating or having operated in the aerospace sector of the Russian Federation economy.

The Treasury statement says that “as a result of today’s action, all property and interests in property of the persons above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.”  In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or blocked persons are prohibited unless authorized by a general or specific license issued by OFAC, or exempt.  These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.

Recall, Reuters said on August 23 that at least $1.2 billion worth of aircraft parts flowed to Russian airlines from May last year - when most U.S. and European trade curbs and export bans over Ukraine were in force - to the end of June this year.

The equipment reportedly ranged from essential items needed to keep a jet airworthy - such as the Northrop Grumman devices, cabin pressure valves, cockpit displays and landing gear - to more mundane spares, such as coffee makers, flight attendant telephone handsets and toilet seats.

Reuters noted that the customs records showed the parts made their way to Russia through middlemen in countries including Tajikistan, the United Arab Emirates (UAE), Turkiye, China and Kyrgyzstan – none of which has endorsed Western sanctions on Russia.

While the customs records don't name the company that shipped the device in November, they reportedly do show how more of the same crucial U.S. parts fitted with high-tech laser gyroscopes reached Urals Airlines during the 14-month period reviewed by Reuters.

In July 2022, for example, one was shipped to Ural Airlines via the UAE by Istikloliyat 20, a civil engineering company based in Tajikistan.  In September 2022, another Tajik civil engineering firm, Kafolati Komil LLC, also sent one of the parts to Russia via the UAE, the data show.