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U.S. Sanctions 12 Kaspersky Executives: Who Was Targeted and What It Means

Treasury’s 2024 action targeted 12 Kaspersky executives, not Kaspersky Lab itself. A separate Commerce measure restricted specified software transactions.
From TheFinanceBase Team4 min to read
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On June 21, 2024, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) designated 12 people in executive and senior leadership roles at AO Kaspersky Lab. The action blocks their covered property within U.S. jurisdiction; Treasury said it did not designate Kaspersky Lab, its parent or subsidiary companies, or its CEO. A separate Commerce Department action restricted specified Kaspersky software transactions. Those are distinct measures with different targets and effects.

What did the U.S. sanctions action do?

Treasury designated 12 individuals under Executive Order 14024 for operating or having operated in the technology sector of the Russian Federation economy. For each designated person, property and interests in property located in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. The designation is an individual sanctions action, not a blanket Treasury designation of the company. Treasury’s June 21, 2024 announcement sets out the action and its stated scope.

Treasury Under Secretary Brian E. Nelson said the action “underscores our commitment to ensure the integrity of our cyber domain and to protect our citizens against malicious cyber threats.” That is the government’s stated rationale; the designation itself does not establish that Kaspersky misused customer data.

Who are the 12 Kaspersky executives Treasury named?

Treasury’s June 21, 2024 release identified the following people and roles:

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  • Andrei Gennadyevich Tikhonov — Chief Operating Officer; also a board member at Kaspersky Lab, its parent organization, and a UK holding company.
  • Daniil Sergeyevich Borshchev — Deputy CEO of Strategy and Economics; previously CFO and Deputy CFO; board member.
  • Andrei Anatolyevich Efremov — Chief Business Development Officer; board member.
  • Igor Gennadyevich Chekunov — Chief Legal Officer; board member.
  • Andrey Petrovich Dukhvalov — Vice President and Director of Future Technologies.
  • Andrei Anatolyevich Suvorov — Head of the Kaspersky Operating System Business Unit.
  • Denis Vladimirovich Zenkin — Head of Corporate Communications.
  • Marina Mikhaylovna Alekseeva — Chief Human Resources Officer.
  • Mikhail Yuryevich Gerber — Executive Vice President of Consumer Business.
  • Anton Mikhaylovich Ivanov — Chief Technology Officer.
  • Kirill Aleksandrovich Astrakhan — Executive Vice President for Corporate Business.
  • Anna Vladimirovna Kulashova — Managing Director for Russia and the Commonwealth of Independent States.

The names and roles above reflect Treasury’s announcement at the time. For a present-day compliance decision, check each name against OFAC’s June 21, 2024 notice and the current SDN List; listing status can change.

Did the U.S. sanction Kaspersky Lab itself?

No—not in Treasury’s June 21 action against the 12 individuals. Treasury explicitly stated that OFAC did not designate Kaspersky Lab, its parent or subsidiary companies, or its CEO. The State Department described the government’s concern that Kaspersky’s privileged access to files and computers could be exploited by the Russian government. That was the government’s stated concern, not independent proof of misuse.

How was the software restriction different?

The Commerce Department’s Bureau of Industry and Security (BIS) announced a separate measure on June 20, 2024 under Executive Order 13873. It restricted specified transactions involving Kaspersky antivirus and cybersecurity products or services in the United States or with U.S. persons. BIS said the determination applied to affiliates, subsidiaries, and parent companies as defined in the determination, and separately added AO Kaspersky Lab, OOO Kaspersky Group, and Kaspersky Labs Limited to the Entity List. These company and transaction measures were not OFAC’s designation of 12 people.

Measure Agency and authority Target Effect
Treasury designations, June 21, 2024 Treasury/OFAC; Executive Order 14024 12 named Kaspersky leaders Blocks their covered property and interests in property within U.S. jurisdiction and requires reporting to OFAC.
Software determination, June 20, 2024 Commerce/BIS; Executive Order 13873 Specified transactions involving Kaspersky products or services, plus three Kaspersky-related entities added to the Entity List Restricts covered software transactions with U.S. persons; it is separate from the individual blocking designations.

BIS allowed certain existing operations, including antivirus signature and codebase updates, during a transition period that ended at 12:00 a.m. EDT on September 29, 2024. Its action page also describes exceptions for specified threat-intelligence, security-training, and purely informational or educational consulting and advisory services. These are details of the Commerce determination, not exceptions to Treasury’s designations. See BIS’s announcement and BIS’s action page for the published scope and terms.

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What did Commerce say about people still using Kaspersky software?

Commerce urged individuals and businesses using Kaspersky software to transition to new vendors. It also said users would not face legal penalties under its determination simply for continuing to use existing products and services, while warning that continued use carried cybersecurity and associated risks. Those statements describe Commerce’s published position, not legal advice about a particular person’s transactions. The cited government materials do not endorse a specific replacement vendor.

What should readers verify before making a decision?

  • For a sanctions-screening or blocked-property question, consult OFAC’s current list and current guidance rather than treating the 2024 notice as confirmation of anyone’s status today.
  • For a question about Kaspersky software transactions, consult current BIS guidance and the determination’s terms; do not assume Treasury’s individual designations and Commerce’s software restrictions have identical scope.
  • For a particular transaction, seek qualified legal or compliance advice. The agencies’ public explanations do not resolve every fact-specific case.

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