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U.S. Sanctions 12 Kaspersky Executives After Covered Sales Ban

Commerce restricted covered Kaspersky products and services in the U.S.; Treasury separately designated 12 executives. Here are the deadlines, exceptions and customer implications.
From TheFinanceBase Team6 min to read
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The U.S. took two different actions against Kaspersky in June 2024: Commerce prohibited specified Kaspersky cybersecurity sales and services to U.S. persons, while Treasury separately sanctioned 12 executives. Treasury’s action did not designate founder and CEO Eugene Kaspersky or Kaspersky Lab itself. The transition deadlines for covered sales, updates and services have passed.

What the United States did—and when

The phrase “sanctioned Kaspersky” can blur three separate Commerce and Treasury measures. The most important distinction is that Commerce restricted specified products and transactions, while Treasury’s June 21 action blocked dealings with named individuals.

Date Action Practical effect
June 20, 2024 The Commerce Department’s Bureau of Industry and Security (BIS) issued a final determination prohibiting covered Kaspersky transactions and added three Kaspersky entities to the Entity List. Covered transactions were phased out under two deadlines.
June 21, 2024 The Treasury Department’s Office of Foreign Assets Control (OFAC) designated 12 Kaspersky executives and senior leaders. The named individuals became subject to U.S. blocking sanctions; this was not a company-wide OFAC designation.
July 20, 2024, 12:00 a.m. EDT The first BIS transition deadline took effect. New covered agreements with U.S. persons were prohibited.
September 29, 2024, 12:00 a.m. EDT The second BIS deadline took effect. Covered updates, Kaspersky Security Network operation for U.S. persons, resale and integration were prohibited.

BIS’s Kaspersky FAQ and final-determination page describes the deadlines and covered activities. The June 20 Commerce announcement and June 21 Treasury announcement explain the separate agency actions.

Was Eugene Kaspersky or Kaspersky Lab sanctioned?

Not by the June 21 OFAC action covered here. Treasury designated 12 individuals, but did not designate Eugene Kaspersky or Kaspersky Lab itself in that announcement. Separately, Commerce prohibited specified transactions involving Kaspersky products and services and placed three entities on its Entity List: AO Kaspersky Lab and OOO Kaspersky Group in Russia, and Kaspersky Labs Limited in the United Kingdom.

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These distinctions matter: saying simply that “Treasury sanctioned Kaspersky” suggests a company designation that the cited OFAC action did not make. Commerce’s restrictions were broad in their covered subject matter, but they were not the same legal action as OFAC’s individual designations.

How the Commerce and Treasury measures differ

Commerce: covered products, services and transactions

BIS’s ICTS final determination prohibited Kaspersky Lab, Inc., its affiliates, subsidiaries and parent companies from directly or indirectly providing specified antivirus and cybersecurity products or services in the United States or to U.S. persons. The determination also addressed new agreements, updates, resale, integration and related activity. It is distinct from the Entity List, which imposes export-control licensing restrictions on specified exports, reexports or transfers to listed entities.

Treasury: restrictions involving designated people

OFAC blocking sanctions generally apply to property and interests in property of designated persons that are in, or come within, U.S. jurisdiction. U.S. persons are generally prohibited from dealing with blocked property or providing funds, goods or services to designated persons where the applicable rules prohibit it. The precise result can depend on the transaction, jurisdiction, property interest, applicable licenses and sanctions rules; this is not a blanket statement that every non-U.S. person is barred from every interaction with every designee.

An Entity List placement, an OFAC designation and a BIS ICTS prohibition are not interchangeable labels. For a transaction-specific compliance decision, organizations should check current BIS and OFAC requirements and obtain qualified legal advice.

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Why Commerce said it acted

Commerce said Kaspersky’s continued U.S. operations presented a national-security risk. Its stated concerns included Russia’s offensive cyber capabilities, the possibility that Russian authorities could influence or direct Kaspersky’s operations, and the extensive file access and elevated privileges antivirus products can have on computers where they are installed. The department said mitigation short of a prohibition was insufficient and described the decision as the first final determination of its kind by the Office of Information and Communications Technology and Services.

Those are the U.S. government’s stated risk assessment and findings. The cited announcement does not establish that Kaspersky software was used in a particular attack against U.S. users or prove that the product was malicious. Treasury described its separate executive designations as a response to cybersecurity risks and an effort to hold accountable leaders who could facilitate or enable activities of concern; it did not say every designee personally conducted cyberattacks.

Who were the 12 OFAC-designated executives?

Treasury’s announcement identifies the following people and describes their leadership roles. Each was designated by OFAC on June 21, 2024.

Person Role or leadership description in Treasury’s announcement Status
Daniil Sergeyevich Borshchev Strategy and economics leadership, with board roles OFAC-designated
Andrei Anatolyevich Efremov Chief business development officer, with board roles OFAC-designated
Andrey Petrovich Dukhvalov Vice president and future-technologies leadership OFAC-designated
Andrei Anatolyevich Suvorov KasperskyOS business-unit leadership OFAC-designated
Denis Vladimirovich Zenkin Corporate communications leadership OFAC-designated
Marina Mikhaylovna Alekseeva Chief human resources officer OFAC-designated
Mikhail Yuryevich Gerber Executive vice president, consumer business OFAC-designated
Anton Mikhaylovich Ivanov Chief technology officer and research and development leadership OFAC-designated
Kirill Aleksandrovich Astrakhan Executive vice president, corporate business OFAC-designated
Anna Vladimirovna Kulashova Regional managing director OFAC-designated
Andrei Gennadyevich Tikhonov Board and chief operating leadership OFAC-designated
Igor Gennadyevich Chekunov Legal leadership and board roles OFAC-designated

The names and roles above follow Treasury’s designation announcement; the designation should not be read as evidence that each person personally carried out cyber operations.

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What the restrictions meant for U.S. customers

The July 20 date covered new agreements; it was not a deadline after which every installed copy instantly stopped opening. The later September 29 deadline was critical for existing users: after it, Kaspersky could not provide covered antivirus signature and codebase updates to U.S. persons or operate Kaspersky Security Network for them. Covered resale and integration activity was also prohibited.

Commerce said an individual or business would not face a legal penalty merely for continuing to use an existing Kaspersky product under the final determination. It nevertheless urged users to move to alternatives and warned that continued use carried cybersecurity and related risks. A product that still launches, or displays an apparently current interface, is not proof that it receives authorized, current protection or vendor support.

Kaspersky said it stopped covered U.S. sales contracts before July 20 and would cease covered updates after September 29. That is the company’s account of its compliance, not a substitute for the scope of BIS rules. See the company’s July 18, 2024 compliance statement.

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Which Kaspersky services were outside the stated prohibition?

BIS said the final determination did not apply to Kaspersky Threat Intelligence products and services, Kaspersky Security Training, or purely informational or educational consulting and advisory services, including certain consulting and incident-response offerings. That does not mean every service sold under the Kaspersky name was exempt. Whether a particular product or contract falls outside the determination depends on what is being supplied and whether the transaction involves covered antivirus or cybersecurity products and services. Organizations should assess the actual service and transaction against the BIS FAQ rather than rely on a broad brand-level assumption.

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What Kaspersky said in response

Kaspersky called the U.S. actions unjustified and baseless, argued that they reflected geopolitical concerns rather than a comprehensive evaluation of its products and operations, and denied that the company or its management had ties to any government. It said it intended to pursue legally available options and proposed independent verification or review mechanisms. These are the company’s claims and proposed responses, not findings established by the U.S. government. Its statements are available in its response to Commerce and response to the OFAC designations.

How organizations can plan a replacement

For U.S. organizations, replacing an endpoint product is a systems and compliance task, not just an uninstall. The following sequence helps surface dependencies and reduce the risk of leaving devices without protection.

  1. Build an inventory. Find Kaspersky agents, servers, appliances, cloud consoles, update mechanisms and embedded integrations. Include virtual desktops, test systems and equipment managed by service providers.
  2. Map contracts and transaction types. Review procurement, reseller, managed-service and integration agreements. Identify which components are covered by the BIS determination and whether a vendor or third party operates them for the organization.
  3. Choose a replacement against operating needs. Compare operating-system and server support, endpoint detection and response capabilities, centralized policy management, identity and SIEM integrations, offline behavior, telemetry controls, data residency, managed detection options, migration tools, support and licensing scope. A consumer antivirus product may not meet a business’s server, investigation or compliance needs.
  4. Test before broad deployment. Pilot the replacement in audit, production, virtual-desktop, server and high-availability environments as relevant. Check conflicts with existing endpoint agents, Windows Security, VPN software and device-management tools.
  5. Move controls and operational context. Recreate policies, exclusions, update settings, alert routing and integrations; retain telemetry and detection history needed for incident response and compliance.
  6. Stage protection and remove stale components. Install and validate the replacement before removing the old agent where feasible. Confirm updates, alerts and management visibility, then remove obsolete agents, consoles, update servers and credentials.

Do not select a replacement solely by antivirus test scores or assume that another vendor is government-approved because it is not Kaspersky. Fit depends on device coverage, staffing, management infrastructure, response workflows and procurement requirements; enterprise pricing and licensing vary by vendor, plan and channel.

Product prices and availability are accurate as of the date/time indicated and are subject to change. Any price and availability information displayed on Amazon at the time of purchase will apply.

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