WASHINGTON — Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated twelve individuals in executive and senior leadership roles at AO Kaspersky Lab (Kaspersky Lab).
“Today’s action against the leadership of Kaspersky Lab underscores our commitment to ensure the integrity of our cyber domain and to protect our citizens against malicious cyber threats,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will take action where necessary to hold accountable those who would seek to facilitate or otherwise enable these activities.”
Yesterday, the Department of Commerce issued a final determination pursuant to Executive Order (E.O.) 13873 prohibiting Kaspersky Lab, Inc., its affiliates, subsidiaries and parent companies directly or indirectly from providing anti-virus software and cybersecurity products or services in the United States or to U.S. persons. Commerce reached this determination after an investigation found transactions involving the products and services of Kaspersky Lab, Inc. and its corporate family pose unacceptable risk to U.S. national security or the safety and security of U.S. persons, as outlined in E.O. 13873.
In addition, the Department of Commerce has designated AO Kaspersky Lab and OOO Kaspersky Group (Russia), and Kaspersky Labs Limited (United Kingdom) on the Entity List for their cooperation with Russian military and intelligence authorities in support of the Russian government’s cyber intelligence objectives. These activities are contrary to U.S. national security and foreign policy interests.
Previously, the Department of Homeland Security issued a binding operational directive that required Federal Executive Branch departments and agencies to discontinue use of and remove Kaspersky Lab-branded products and services, as defined, from their information systems. This action was based on information that identified the security risks presented by the use of Kaspersky Lab products on Federal information systems. Kaspersky Lab’s anti-virus products and solutions provide broad access to files and elevated privileges on the computers on which the software is installed, which can be exploited by malicious cyber actors to compromise those information systems.
Kaspersky Lab Board of Directors and Senior Executives and Leadership
All the individuals below were designated pursuant to E.O. 14024 for operating in the technology sector of the Russian Federation economy.
Andrei Gennadyevich Tikhonov (Tikhonov) is a member of the boards of directors of Kaspersky Lab, its parent organization OOO Kaspersky Group (Kaspersky Group), as well as the United Kingdom-based holding company Kaspersky Limited. Since January 2012, Tikhonov has served as Kaspersky Lab’s Chief Operating Officer (COO), a position that is responsible for the global administrative functions of the company. The COO is a member of Kaspersky Lab’s Executive Team and is directly subordinate to the company’s Chief Executive Officer (CEO).
Daniil Sergeyevich Borshchev (Borshchev) is a member of the boards of directors of Kaspersky Lab, Kaspersky Group, and Kaspersky Limited. In March 2017, he was appointed Kaspersky Lab’s Deputy CEO of Strategy and Economics, which is responsible for long term economic strategic issues, developing the company’s global economic landscape, and internal audits. The Deputy CEO of Strategy and Economics is a member of the company’s Executive Team, which is directly subordinate to the CEO. Borshchev has also served as Kaspersky Lab’s Chief Financial Officer (CFO) and Deputy CFO.
Andrei Anatolyevich Efremov (Efremov) is a member of the boards of directors of Kaspersky Lab and Kaspersky Group and is also the company’s Chief Business Development Officer (CBDO). The CBDO is responsible for the technological development and business results of Kaspersky Lab, and is a member of the company’s Executive Team, which is directly subordinate to the CEO.
Igor Gennadyevich Chekunov (Chekunov) is a member of the boards of directors of Kaspersky Lab and Kaspersky Group and is the company’s Chief Legal Officer (CLO). The CLO is responsible for the legal oversight of all the company’s activities, and certain departments, such as the Computer Incidents Investigation, Security, and Intellectual Property Control, operate under the CLO’s leadership. The CLO is also a member of Kaspersky Lab’s Executive Team and is directly subordinate to the CEO.
Andrey Petrovich Dukhvalov (Dukhvalov) is Kaspersky Lab’s Vice President and Director of Future Technologies. The Vice President is a member of the company’s Executive Team and is directly subordinate to the CEO.
Andrei Anatolyevich Suvorov (Suvorov) is Kaspersky Lab’s Head of Kaspersky Operating System Business Unit, a role which is a member of the company’s Executive Team and is directly subordinate to the CEO.
Denis Vladimirovich Zenkin (Zenkin) is the Kaspersky Lab’s Head of Corporate Communications, a role which is a member of the company’s Executive Team and directly subordinate to the CEO.
Marina Mikhaylovna Alekseeva (Alekseeva) is Kaspersky Lab’s Chief Human Resources (HR) Officer (CHRO), a role which is a member of the Executive Team and directly subordinate to the COO. As CHRO, Alekseeva is responsible for Kaspersky Lab’s HR strategy on a global level and overseeing “Kaspersky Academy,” which provides training for the company’s employees, customers, and partners.
Mikhail Yuryevich Gerber (Gerber) is Kaspersky Lab’s Executive Vice President of Consumer Business, a role that is part of the company’s Executive Team and is directly subordinate to the CBDO. He is responsible for the development of Kaspersky Lab’s business-to-consumer products on several operating systems.
Anton Mikhaylovich Ivanov (Ivanov) heads Kaspersky Lab’s research and development department as the company’s Chief Technology Officer (CTO). The CTO is part of the company’s Executive Team, directly subordinate to the CBDO.
Kirill Aleksandrovich Astrakhan (Astrakhan) is Kaspersky Lab’s Executive Vice President for Corporate Business, a position which is part of the company’s Executive Team and subordinate to the CBDO. In this role, Astrakhan is responsible for leading the development and growth of the company’s corporate sales.
Anna Vladimirovna Kulashova (Kulashova) is Kaspersky Lab’s Managing Director for Russia and the Commonwealth of Independent States (CIS), a position that is part of the company’s senior leadership team and is directly subordinate to the Executive Vice President for Corporate Business. Kulashova is responsible for developing the direction of corporate sales and strengthening the company’s position in the field of protection against complex cyber threats in Russia and CIS countries.
Tikhonov, Borshchev, Efremov, Chekunov, Dukhvalov, Suvorov, Zenkin, Alekseeva, Gerber, Ivanov, Astrakhan, and Kulashova are designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy.
OFAC has not designated Kaspersky Lab, its parent or subsidiary companies, or its CEO.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated persons described 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, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons. 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.
In addition, foreign financial institutions that conduct or facilitate significant transactions or provide any service involving Russia’s military-industrial base run the risk of being sanctioned by OFAC. For additional guidance, please see the updated OFAC advisory, “Updated Guidance for Foreign Financial Institutions on OFAC Sanctions Authorities Targeting Support to Russia’s Military-Industrial Base,” as well as OFAC Frequently Asked Questions (FAQs) 1146-1157.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897. For detailed information on the process to submit a request for removal from an OFAC sanctions list.
For identifying information on the individuals and entities designated today, click here.
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