06 July 2020 NOTICE RE: Financial Sanctions Notice The Cayman Islands Monetary Authority (“CIMA”) hereby notifies you that it has received a new Notice from the Office of Financial Sanctions Implementation, HM Treasury (“OFSI”), which is attached as an Annex to this Notice. 1. What you must do: A. In the case of an addition or amendment of a person to the Consolidated List and asset freeze: i. Check whether you maintain any accounts or hold any funds or economic resources for the persons set out in the OFSI Notice; ii. Freeze any such accounts and other funds or economic resources. iii. Refrain from dealing with the funds or assets or making them available (directly or indirectly) to such persons unless licensed by the Governor. iv. Report any findings to the Financial Reporting Authority (“FRA”) at [email protected] together with any additional information that would facilitate compliance with the relevant legislative requirements. v. Provide any information concerning the frozen assets of designated persons to the FRA at [email protected] and submitting a compliance reporting form. Information reported to FRA may be passed to other regulatory authorities or law enforcement. B. In the case of the removal of a person from the Consolidated List and unfreezing of assets i. Check whether you have frozen assets of any person or entity removed from the Consolidated List and verify that the person is no longer subject to an asset freeze. ii. Remove the person from your institution’s list of persons or entities subject to financial sanction. iii. Un-freeze the assets of the person and where necessary re-activate all relevant accounts. SIX, Cricket Square P.O. Box 10052 Grand Cayman KY1–1001, Cayman Islands Tel +1 345 949-7089 www.cima.ky iv. Send advice to the person that the assets are no longer subject to an asset freeze. v. Advise the FRA at [email protected] of the actions taken. 2. Failure to comply with financial sanctions legislation or to seek to circumvent its provisions is a criminal offence. Further Information. For general information on financial sanctions please see FRAs Industry Guidance on targeted financial sanctions. http://fra.gov.ky/app/webroot/files/2017-12-FRAGuidanceTargetedFinancialSanction.pdf. Enquiries regarding this sanctions notice should be addressed to The Sanctions Coordinator Financial Reporting Authority P.O. Box 1054 Grand Cayman KY1-1102 Cayman Islands [email protected] REGIME: Global Human Rights INDIVIDUAL 1. Names (Last): Kratov (1): Dmitry (2): Borisovich (3): n/a (4): n/a (5): n/a Title: Doctor Position: Chief Medical Officer and Deputy Head of Butyrka Prison A.K.A: Doctor Kratov Dimitry Borisovich Date of Birth: 19/07/1964 Place of Birth: n/a Nationality: Russian Passport Details: n/a Address: n/a Other Information UK Sanctions List Ref: GHR0001. Gender: male. Dmitry Borisovich Kratov, who was the Chief Medical Officer and Deputy Head of Butyrka Prison where Magnitsky was detained until shortly before his death on 16 November 2009, was responsible for the mistreatment of Sergei Magnitsky, including by failing to ensure the proper administration of medical care, which contributed significantly to his death. UK listing (Sanctions Act). Subject to an asset freeze and travel ban. Listed On: 06/07/2020 Last Updated: 06/07/2020 Group ID: 13852 2. Names (Last): Anichin (1): Aleksey (2): Vasilyevich (3): n/a (4): n/a (5): n/a Title: n/a Position: n/a A.K.A: Anichin Alexei Vasilyevich Date of Birth: 01/12/1949 2 Place of Birth: Sevastopol Nationality: Russian Passport Details: n/a Address: n/a Other Information UK Sanctions List Ref: GHR0002. Gender: male. Aleksey Vasilyevich Anichin, as a deputy Minister in the Russian Interior Ministry and the head of the Investigative Committee, was involved in the mistreatment of Sergei Magnitsky whilst in detention, which contributed significantly to his death on 16 November 2009. Anichin oversaw a ‘team’ of investigators who failed to investigate complaints made by Magnitsky about his mistreatment and concealed evidence of Magnitsky’s deteriorating medical condition. UK listing (Sanctions Act). Subject to an asset freeze and travel ban. Listed On: 06/07/2020 Last Updated: 06/07/2020 Group ID: 13853 3. Names (Last): Silchenko (1): Oleg (2): F. (3): n/a (4): n/a (5): n/a Title: Lt. Col Position: Investigator in the Investigative Committee A.K.A: n/a Date of Birth: 25/06/1977 Place of Birth: Samarkand Nationality: n/a Passport Details: n/a Address: n/a Other Information UK Sanctions List Ref: GHR0003. Gender: male. Oleg Silchenko was an investigator in the Investigative Committee of the Russian Interior Ministry and was directly involved in the mistreatment of Sergei Magnitsky whilst in detention, which contributed significantly to his death on 16 November 2009. Silchenko made six applications to extend Magnitsky’s detention period (despite his deteriorating medical condition), refused Magnitsky access to his family and engaged in the oppressive questioning and other mistreatment of Magnitsky to pressurise him to retract his allegations of corruption against Interior Ministry officials. UK listing (Sanctions Act). Subject to an asset freeze and travel ban. Listed On: 06/07/2020 Last Updated: 06/07/2020 Group ID: 13854 4. Names (Last): Al Balawi (1): Fahad (2): Shabib (3): A. (4): n/a (5): n/a Title: n/a Position: Member of the Royal Guard A.K.A: n/a Date of Birth: 24/01/1985 Place of Birth: Arar Nationality: Saudi Arabian Passport Details: N163990 Address: n/a Other Information UK Sanctions List Ref: GHR0026. Gender: male. Fahad Shabib A. Albalawi was a Royal Guard in Saudi Arabia. He was directly involved in carrying out the 3 unlawful killing of Jamal Khashoggi at the Saudi Consulate in Istanbul on 2 October 2018, as part of the 15 man team sent to Turkey by Saudi authorities. UK listing (Sanctions Act). Subject to an asset freeze and travel ban. Listed On: 06/07/2020 Last Updated: 06/07/2020 Group ID: 13855 5. Names (Last): Karlov (1): Gennady (2): Vyacheslavovich (3): n/a (4): n/a (5): n/a Title: Colonel Position: Head of Department of Ownership and Financial Crimes in the Investigative Committee of the Russian Interior Ministry A.K.A: n/a Date of Birth: 27/02/1960 Place of Birth: n/a Nationality: Russian Passport Details: n/a Address: n/a Other Information UK Sanctions List Ref: GHR0004. Gender: male. Gennady Karlov, as the Head of the Department of Ownership and Financial Crimes in the Investigative Committee of the Russian Ministry of Interior, was involved in the mistreatment of Sergei Magnitsky whilst in detention, which contributed significantly to his death. Karlov was part of a ‘team’ of investigators who failed to investigate complaints made by Magnitsky about his mistreatment and approved actions to conceal evidence relating to subordinates who were directly involved in that conduct. UK listing (Sanctions Act). Subject to an asset freeze and travel ban. Listed On: 06/07/2020 Last Updated: 06/07/2020 Group ID: 13856 6. Names (Last): Alharbi (1): Thaar (2): Ghaleb (3): T. (4): n/a (5): n/a Title: n/a Position: Lieutenant A.K.A: n/a Date of Birth: 01/08/1979 Place of Birth: Riyadh Nationality: Saudi Arabian Passport Details: P723557 Address: n/a Other Information UK Sanctions List Ref: GHR0027. Gender: male. Thaar Ghaleb T. Alharbi held the rank of Lieutenant, though it is not clear in which part of the Saudi forces this was and his official role is not clear. He was present during the unlawful killing of Jamal Khashoggi in the Saudi Consulate in Istanbul on 2 October 2018, and played an active part in the 15 man team sent to Turkey by Saudi authorities. UK listing (Sanctions Act). Subject to an asset freeze and travel ban. Listed On: 06/07/2020 4 Last Updated: 06/07/2020 Group ID: 13857 7. Names (Last): Vinogradova (1): Natalya (2): n/a (3): n/a (4): n/a (5): n/a Title: Colonel Position: Deputy Head of Department of Ownership and Financial Crimes in the Investigative Committee in Russian Ministry of Internal Affairs A.K.A: n/a Date of Birth: 16/06/1973 Place of Birth: n/a Nationality: Russian Passport Details: n/a Address: n/a Other Information UK Sanctions List Ref: GHR0005. Gender: female. Natalya Vinogradova, as the Deputy Head of the Ownership and Financial Crimes Department in the Investigative Committee of the Russian Interior Ministry, was involved in the mistreatment of Sergei Magnitsky, which contributed significantly to his death on 16 November 2009. Vinogradova was part of a ‘team’ of investigators, who failed to investigate complaints made by Magnitsky about his mistreatment and provided support to subordinates who were directly involved in that conduct. UK listing (Sanctions Act). Subject to an asset freeze and travel ban. Listed On: 06/07/2020 Last Updated: 06/07/2020 Group ID: 13858 8. Names (Last): Tagiyev (1): Fikret (2): n/a (3): n/a (4): n/a (5): n/a Title: n/a Position: Head of Matrosskaya Tishina Detention Facility A.K.A: (1) Tagiev Fikhret, (2) Tagiev Fikret, (3) Tagiev Fikhret Gabdulla Ogly, (4) Tagiyev Fikhret Gabdulla Ogly, (5) Tagiyev Fikhret, (6) Taguev Fikret, (7) Taguev Fikhret, (8) Taguev Fikhret Gabdulla Ogly Date of Birth: 03/04/1962 Place of Birth: Baku Nationality: Russian Passport Details: n/a Address: n/a Other Information UK Sanctions List Ref: GHR0006. Gender: male. Fikret Tagiyev was the head of the Matrosskaya Tishina detention centre where Sergei Magnitsky died on 16 November 2009. He was responsible for the mistreatment of Sergei Magnitsky whilst in detention, which contributed significantly to his death including by failing to ensure the provision of adequate medical treatment, ordering the handcuffing and beating of Magnitsky shortly before his death and denying, or failing to provide, timely access for emergency services to provide treatment.