| Entity | Persons related to the Russian Federation (33 entities and 9 individuals); list no. 402 is Garantex Europe OU (alias: Garantex) |
|---|---|
| Counterparty | 4 entities outside the Russian Federation and the Republic of Belarus (list nos. 57–60); 35 vessels |
| Date | 2 Oct 2026 |
| Status | Designated |
| Instrument | Cabinet understanding "Regarding Asset Freeze and Other Measures against Persons Related to the Russian Federation" (2 October 2026); Ministry of Foreign Affairs notice (issued 2 October); Foreign Exchange and Foreign Trade Act |
| Region | U.S. & Allies |
On 2 October 2026 the Ministry of Foreign Affairs, the Ministry of Finance, and the Ministry of Economy, Trade and Industry implemented measures under the Foreign Exchange and Foreign Trade Act, pursuant to that day’s Cabinet understanding on asset freezes and other measures against persons related to the Russian Federation.
The package puts payments and specified capital transactions with 33 Russian entities and 9 individuals on a permission basis, prohibits exports to 4 entities outside Russia and Belarus, puts services and vessel-related capital transactions for 35 vessels on a permission basis, and introduces a prohibition on exports of items that contribute to strengthening the industrial base of the Russian Federation. List no. 402 in the asset-freeze annex is Garantex Europe OU, alias Garantex.
Who this affects
- For exporters: Payments to the 33 entities and 9 individuals listed in the 2 October Ministry of Foreign Affairs notice require permission, and exports to the 4 listed entities outside Russia and Belarus are prohibited.
- For investors: Deposit, trust, and loan contracts with the listed persons require permission; loans and debt guarantees tied to the purchase or sale of the 35 listed vessels require permission.
- For counsel/compliance: The release applies the measures from 2 October 2026, except performance of obligations under contracts concluded before that date, or provision of labor or benefits, carried out before 1 November 2026.
- For policymakers: The Cabinet understanding is framed as Japan’s contribution to international efforts toward peace on Ukraine, taking account of measures major countries decided to take.
The read
The same 2 October Ministry of Foreign Affairs notice that lists machine-building, radio-engineering, and Alabuga-named entities also lists Garantex Europe OU (St. Petersburg; Federation East Tower, Moscow City) as entity 402, and a separate annex prohibits exports to one Turkish entity and three UAE entities. The industrial-base export prohibition is introduced in this release without an item schedule. The entity annex is headed as entities excluding specified banks; Rostec, LLC TROS, and LLC CST appear only as affiliations of listed individuals, not as entries 370–402.
What was the action?
The three ministries decided to implement four measures under the Foreign Exchange and Foreign Trade Act, based on the 2 October 2026 Cabinet understanding. Asset-freeze measures cover the 33 entities and 9 individuals in the Ministry of Foreign Affairs notice. Export prohibitions cover 4 entities outside Russia and Belarus. Service and capital-transaction controls cover 35 vessels. A prohibition is introduced on exports of items that contribute to strengthening Russia’s industrial base.
What’s the penalty / scope, and how is it set?
No monetary penalty is stated. Payments to listed persons, and capital transactions with them (deposit contracts, trust contracts, and money-loan contracts), are made subject to permission. Exports to the 4 third-country entities are prohibited. Services to the 35 vessels, as defined in a Ministry of Finance notice, and loans and debt guarantees associated with purchase or sale of those vessels, are made subject to permission. The industrial-base measure is an export prohibition; the goods covered are not specified in this release. Application is from 2 October 2026, with the pre-1 November 2026 exception for performance under contracts concluded before 2 October.
Who else is exposed?
The asset-freeze annex (nos. 370–402) names Russian industrial entities including Kaluga Research Institute of Radio Engineering JSC, JSC UEC Star / JSC ODK-Star, Alabuga Development OOO, LLC Alabuga Machinery, LLC Drake (Alabuga), LLC Uraldronzavod, JSC Tula Machine Building Plant, the Lobaev Foundation, and Garantex Europe OU. The 9 individuals (nos. 760–768) include Vladislav Kostin (General Director, JSC VNIIR Progress), Artem Yamshchikov (General Director, OOO TSK Vektor), Dmitry Lelikov (Deputy General Director, Rostec), Vasily Brovko (Director, Rostec), Igor Khomenko and Sergei Ushko (LLC TROS), Vladislav Lobaev (former president, Lobaev Foundation), Aleksandr Sychugov (General Director, JSC Voskresensky Aggregation Factory), and Aleksandr Zakharov (owner, LLC CST). Export prohibitions cover Solid Tarim Inovasyon Anonim Sirketi (Alanya, Turkey), Amegino FZE (Ras Al Khaimah), Auto Parts East FZCO (Jebel Ali), and MOTO Export DWC LLC (Dubai). Annex 3 lists 35 vessels by IMO number, from 9179842 through 9341079.
What happens next
The stated application date is 2 October 2026. Performance under contracts concluded before that date is outside the measures only if carried out before 1 November 2026. The release does not set out the goods schedule for the industrial-base export prohibition, or the text of the Ministry of Finance notice that defines vessel services.