The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has sanctioned Dmitry Kudryakov, a Russian national, and Iryna Litviniuk, a Belarusian national, for their role in the Guatemalan mining sector, as well as three associated entities—Compania Guatemalteca de Niquel (“CGN”), Compania Procesadora de Niquel (“ProNiCo”), and Mayaniquel—connected with certain corruption schemes. CNG, ProNiCo, and Mayaniquel function as subsidiaries of the Solway Investment group (“Solway”), a Russian enterprise that, the Treasury Department says, has exploited Guatemalan mines since 2011. The leader of Solway’s mining operations in Guatemala, Kudryakov, along with Litviniuk, allegedly led multiple bribery schemes over several years involving politicians, judges, and government officials. In addition, Litviniuk is alleged to have conducted corrupt acts in furtherance of Russian influence-peddling schemes by unlawfully giving cash payments to public officials in exchange for support for Russian mining interests.

Kudryakov, Litviniuk, and the three companies registered in Guatemala are designated pursuant to Executive Order (“E.O.”) 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act and targets perpetrators of serious human rights abuse and corruption around the world. Specifically, Kudryakov and Litviniuk are designated for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of corruption, including the misappropriation of state assets, corruption related to government contracts.   As a result of their designation as Specially Designated Nationals, all property and assets of the designated companies and individuals, within the United States or under the control or custody of US person, are blocked, and US persons are prohibited from engaging in or facilitating business dealings with the designated persons and companies, or with any entity 50% or more owned by them.

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Jonathan Cross
Jonathan Cross
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Christopher Boyd
Christopher Boyd
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Brittany Crosby-Banyai
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Kelechi Okengwu
Kelechi Okengwu
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Kelly Adams
Law Clerk, New York
+1 917 542 7854