[Federal Register Volume 88, Number 218 (Tuesday, November 14, 2023)]
[Notices]
[Pages 77955-77959]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2023-25005]


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DEPARTMENT OF COMMERCE

Bureau of Industry and Security


Nikolay Goltsev, a/k/a Nick Stevens, a/k/a Gio Ross, 107 Rue 
Caron, Ste-Anne-De-Bellevue, Quebec, Canada H9X4A1; Salimdzhon 
Nasriddinov, 3734 Laurel Ave., Brooklyn, NY 11224; Kristina Puzyreva, 
107 Rue Caron, Ste-Anne-De-Bellevue, Quebec, Canada H9X4A1; Vladimir 
Bochkarev, Privolnaya Street 75, Korp.1, Apt. 173, Moscow, Russia; 
Pavel Chernikov, Zoologicheskiy Pereulok 9/11. Apt. 13, Moscow, Russia 
123242; Yekaterina Vetoshkina, Ulitsa Privolnaya 75/1, Apt. 173, 
Moscow, Russia, 109431; Oleg Zenchenko, Vesenniya Street 16, Taytsy, 
Petersburg Region, Russia and Kupchinskaya Street 29/1, Apt. 363, St. 
Petersburg, Russia 192283; SH Brothers Group, Inc., 3734 Laurel Ave., 
Brooklyn, NY 11224; SN Electronics, Inc., 2650 AB Coney Island Ave., 
Brooklyn, NY 11223; Suntronic F.Z.E., Shiekh Khalifa Bin Zayed, St-
Amberjem Tower E1/913, Ajman, United Arab Emirates; Order Temporarily 
Denying Export Privileges

    Pursuant to section 766.24 of the Export Administration Regulations 
(the ``Regulations'' or ``EAR''),\1\ the Bureau of Industry and 
Security (``BIS''), U.S. Department of Commerce, through its Office of 
Export Enforcement (``OEE''), has requested the issuance of an Order 
temporarily denying, for a period of 180 days, the export privileges 
under the Regulations of: Nikolay Goltsev, Salimdzhon Nasriddinov, 
Kristina Puzyreva, Vladimir Bochkarev, Pavel Chernikov, Yekaterina 
Vetoshkina, Oleg Zenchenko, SH Brothers Group, Inc. (``SH Brothers''), 
SN Electronics, Inc. (``SN Electronics''), and Suntronic FZE 
(``Suntronic''). OEE's request and related information indicates that 
these parties are located in New York, the Russian Federation and the 
United Arab Emirates (``U.A.E.''), at the respective addresses listed 
on the caption page of this order and on page 16, infra.
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    \1\ The Regulations, currently codified at 15 CFR parts 730 
through 774 (2023), originally issued pursuant to the Export 
Administration Act (50 U.S.C. 4601-4623 (Supp. III 2015) (``EAA''), 
which lapsed on August 21, 2001. The President, through Executive 
Order 13222 of August 17, 2001 (3 CFR, 2001 Comp. 783 (2002)), as 
extended by successive Presidential Notices, continued the 
Regulations in effect under the International Emergency Economic 
Powers Act (50 U.S.C. 1701, et seq. (2012)) (``IEEPA''). On August 
13, 2018, the President signed into law the John S. McCain National 
Defense Authorization Act for Fiscal Year 2019, which includes the 
Export Control Reform Act of 2018, 50 U.S.C. 4801-4852 (``ECRA''). 
While section 1766 of ECRA repeals the provisions of the EAA (except 
for three sections which are inapplicable here), section 1768 of 
ECRA provides, in pertinent part, that all orders, rules, 
regulations, and other forms of administrative action that were made 
or issued under the EAA, including as continued in effect pursuant 
to IEEPA, and were in effect as of ECRA's date of enactment (August 
13, 2018), shall continue in effect according to their terms until 
modified, superseded, set aside, or revoked through action 
undertaken pursuant to the authority provided under ECRA. Moreover, 
section 1761(a)(5) of ECRA authorizes the issuance of temporary 
denial orders.
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I. Legal Standard

    Pursuant to section 766.24, BIS may issue an order temporarily 
denying a respondent's export privileges upon a showing that the order 
is necessary in the public interest to prevent an ``imminent 
violation'' of the Regulations. 15 CFR 766.24(b)(1) and 766.24(d). ``A 
violation may be `imminent' either in time or degree of likelihood.'' 
15 CFR 766.24(b)(3). BIS may show ``either that a violation is about to 
occur, or that the general circumstances of the matter under 
investigation or case under criminal or administrative charges 
demonstrate a likelihood of future violations.'' Id. As to the 
likelihood of future violations, BIS may show that the violation under 
investigation or charge ``is significant, deliberate, covert and/or 
likely to occur again, rather than technical or negligent[.]'' Id. A 
``[l]ack of information establishing the precise time a violation may 
occur does not preclude a finding that a violation is imminent, so long 
as there is sufficient reason to believe the likelihood of a 
violation.'' Id.

II. OEE'S Request for a Temporary Denial Order

    The U.S. Commerce Department, through BIS, responded to the Russian 
Federation's (``Russia's'') further invasion of Ukraine by implementing 
a sweeping series of stringent export controls that severely restrict 
Russia's access to technologies and other items that it needs to 
sustain its aggressive military capabilities. These controls primarily 
target Russia's defense, aerospace, and maritime sectors and are 
intended to cut off Russia's access to vital technological inputs, 
atrophy key sectors of its industrial base, and undercut Russia's 
strategic ambitions to exert influence on the world stage.
    As of February 24, 2022, any item classified under any Export 
Classification Control Number (``ECCN'') in Categories 3 through 9 of 
the Commerce Control List (``CCL'') required a license to be exported 
or reexported to Russia. See 87 FR 12226 (Mar. 3, 2022). As of April 8, 
2022, the license requirements for Russia were expanded to cover all 
items on the CCL. See 87 FR 22130 (Apr. 14, 2022). These rules were 
codified in 15 CFR 746.8, which state, ``a license is required, 
excluding deemed exports and deemed reexports, to export, reexport, or 
transfer (in-country) to or within Russia or Belarus any item subject 
to the EAR and specified in any Export Control Classification Number 
(ECCN) on the CCL.''
    BIS has imposed additional license requirements for exports, 
reexports and transfers to or within Russia of any items subject to the 
EAR that were identified under certain Schedule B or Harmonized Tariff 
Schedule 6 (``HTS'') numbers under Supplement No. 4 to Part 746--
Russian and Belarusian Industry Sector Sanctions Pursuant to Sec.  
746.5(a)(1)(ii).\2\ HTS codes take their first six digits from the 
corresponding Harmonized System (``HS'') code, a standardized numerical 
method of classifying traded products used by customs authorities 
around the world. On September 14, 2023, working in conjunction with 
the United Kingdom and European Union, BIS published a ``Common High 
Priority Items List,'' which identified items by their corresponding 
HTS codes listed in Supp. No. 4 to Part 746 that Russia sought to 
procure for its weapons programs.\3\
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    \2\ See, e.g., 87 FR 12856 (March 8, 2022).
    \3\ See https://www.bis.doc.gov/index.php/all-articles/13-policyguidance/country-guidance/2172-russia-export-controls-list-of-common-high-priority-items. Note that additional HTS codes were 
added to Supp. No. 4 to Part 746, including for items identified on 
the ``Common High Priority Items List,'' pursuant to several Federal 
Register notices. See 87 FR 57068 (Sep. 16, 2022); 88 FR 12175 (Feb. 
27, 2023); and 88 FR 33922 (May 23, 2023).

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[[Page 77956]]

    On or about November 6, 2023, Goltsev, Nasriddinov, Puzyreva, 
Bochkarev, Chernikov, Vetoshkina, and Zenchenko (collectively ``the co-
conspirators'') were each indicted on multiple counts in the United 
States District Court for the Eastern District of New York. The charges 
include, but are not limited to, conspiring to violate U.S. export 
control laws in connection with the unlicensed export of items on the 
CCL and Supp. No. 4 to Part 746. The co-conspirators are also charged 
with smuggling, as well as failure to file and filing false Electronic 
Export Information (``EEI'').\4\
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    \4\ The co-conspirators are also charged with, inter alia, 
conspiracy to defraud the United States, wire fraud and wire fraud 
conspiracy, and money laundering conspiracy.
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    In its request, OEE has presented evidence indicating that, between 
at least on or about January 2022 and October 2023, Goltsev, 
Nasriddinov, Puzyreva, Bochkarev, Chernikov, Vetoshkina, and Zenchenko 
conspired to violate ECRA and the EAR by unlawfully sourcing and 
exporting millions of dollars in dual-use electronics from the United 
States for export to Russia without the required licenses. In instances 
where a particular item may not have required an export license, the 
co-conspirators also made, and caused to be made, false and misleading 
statements with respect to EEI filings in order to conceal the ultimate 
end destination and end user.
    As alleged in the indictment, Goltsev and Nasriddinov sourced and 
purchased U.S.-origin electronics at the direction of Russian 
procurement agents, including Bochkarev, Chernikov, Vetoshkina, and 
Zenchenko. Goltsev, Nasriddinov, and Puzyreva utilized U.S.-registered 
companies, SH Brothers Group, Inc. and SN Electronics, Inc., both 
located in Brooklyn, NY, as part of the procurement scheme. Before 
ultimate diversion to Russia, some of these items were shipped to 
third-country transshipment companies, including Suntronic, a front 
company located in the United Arab Emirates and utilized by Bochkarev. 
Based on the facts alleged in the indictment, Goltsev, Nasriddinov, 
Puzyreva, Bochkarev, Chernikov, Vetoshkina, and Zenchenko were aware of 
U.S. export control laws and took affirmative action to conceal their 
unlawful export-related activities in order to deceive U.S. 
manufacturers and distributors, and to evade detection by law 
enforcement.

A. The Unlawful Procurement Scheme

    As further alleged in the indictment, several of the co-
conspirators worked to procure items on behalf of various Russian 
entities. For example, until in or about August 2022, Vetoshkina, a 
Russian national residing in Russia, served as a procurement manager 
for OOO \5\ Radioavtomatika (``Radioavtomatika''), a Russian defense 
procurement firm based in Moscow. Radioavtomatika was added to the BIS 
Entity List on or about March 3, 2022.\6\ Vetoshkina then began working 
for OOO Komtech (``Komtech''), a Moscow-based electronics distributor.
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    \5\ ``OOO'' is the abbreviation for the Russian business entity 
type ``[ocy][bcy][shchcy][iecy][scy][tcy][vcy][ocy] [scy] 
[ocy][gcy][rcy][acy][ncy][icy][chcy][iecy][ncy][ncy][ocy][jcy] 
[ocy][tcy][vcy][iecy][tcy][scy][tcy][vcy][iecy][ncy][ncy][ocy][scy][t
cy][softcy][yucy],'' which means limited private company and is 
roughly the equivalent of a limited liability company or LLC in the 
United States.
    \6\ See 87 FR 13141 (Mar. 9, 2022).
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    Chernikov, a Russian national residing in Russia, conducted 
procurement operations for OOO Testkomplekt (``Testkomplekt''), another 
Moscow-based electronics distributor that has held contracts with 
Russian military entities. Testkomplekt was added to OFAC's Specially 
Designated Nationals (``SDN'') list on or about May 19, 2023, pursuant 
to Executive Order 14024.\7\ Similarly, Zenchenko conducted procurement 
operations for OOO NEVA-EKB (``EKB-Neva''), a Moscow-based electronics 
supplier, which was added to OFAC's SDN list on or about May 19, 2023, 
pursuant to Executive Order 14024. Goltsev, a Russian national residing 
in Canada, also had long-standing relationships with Radioavtomatika, 
Testkomplekt, EKB-NEVA and other Russia-based entities, and had 
procured electronic components for them for years.
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    \7\ https://home.treasury.gov/news/press-releases/jy1494.
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    Based on evidence presented by OEE and as further stated in the 
indictment, Bochkarev, Chernikov, Vetoshkina, and Zenchenko received 
orders from Russian end users in the defense and technology sectors 
seeking to acquire U.S.-origin items. They then relayed these requests 
to Goltsev, who used aliases, including ``Nick Stevens'' and ``Gio 
Ross,'' to communicate with U.S. manufacturers and distributors. In 
these communications, Goltsev made material misrepresentations about 
the transactions, including about the ultimate end use and end users, 
as well as the parties involved in the transactions. Goltsev and 
Nasriddinov, a dual-national of Russia and Tajikistan residing in New 
York, purchased the items from U.S. companies. Nasriddinov received the 
items at various addresses in Brooklyn, New York and supervised their 
repackaging. To further the scheme, Puzyreva, Goltsev's spouse, 
utilized numerous bank accounts, including one that listed 
Nasriddinov's home address as the address of record.
    After repackaging the items, Nasriddinov and Goltsev then exported 
the items from the United States for transshipment to Russia and 
Russian end users, including Radioavtomatika, Komtech, Testkomplekt, 
and EKB-NEVA. Using SH Brothers and SN Electronics, Nasriddinov and 
Goltsev shipped the items through various intermediaries located in 
third countries, including China, India, Turkey, and the United Arab 
Emirates. One such intermediary was Suntronic, located in the U.A.E. 
and used by Bochkarev to conduct multiple procurement operations for 
Russian entities.
    As part of the scheme, Goltsev, Nasriddinov, Puzyreva, Bochkarev, 
Chernikov, Vetoshkina, and Zenchenko also made, and caused to be made, 
material misrepresentations and omissions, including with respect to 
EEI filings, to conceal the unlawful procurement transactions. As a 
result of their actions, the co-conspirators caused U.S. companies to, 
among other things, sell and export electronic components in violation 
of ECRA and the EAR.
    Some of the items sourced and exported by Goltsev, Nasriddinov, 
Puzyreva, Bochkarev, Chernikov, Vetoshkina, and Zenchenko included 
electronic components and integrated circuits listed in Supp. No. 4 to 
Part 746 of the EAR and requiring a license to Russia, which have been 
designated as ``Tier 1'' items on the Common High Priority Items List. 
These priority items pose a heightened risk of being diverted illegally 
to Russia because of their importance to Russia's war efforts.

B. Knowledge of U.S. Export Controls and Intent To Evade

    As further alleged in the indictment, communications between the 
co-conspirators indicate that they had knowledge of U.S. export 
controls and made efforts to conceal their unlawful procurement. For 
example, in or about October 2021, after Vetoshkina advised Goltsev 
that paperwork for an order of electronics stated that the items were 
destined for Russia, Goltsev advised her to use a Hong Kong-based 
company as the ``bill-to'' and confirmed that he would nonetheless ship 
the items to Radioavtomatika. In another communication to Goltsev in or 
about October 2022, Vetoshkina's employee listed several different 
electronic components, including coaxial switches and capacitors, that 
required a license to

[[Page 77957]]

be shipped to Russia and stated, ``please tell me do you have these 
goods, priceless in Russia.'' Goltsev responded with price quotations 
for the items.
    Based on facts alleged in the indictment, other communications 
between Goltsev and Russian procurement agents, including Chernikov, 
demonstrate a knowledge of export control laws and sanctions, as well 
as an intent to conceal. For example, in a December 2022 text message 
exchange with Chernikov regarding an order placed through SH Brothers, 
Goltsev requested ``separate invoices. . .the ECCN[s] aren't very 
pretty. We'll ship them piecemeal.'' In another communication in or 
about February 28, 2023, Goltsev mentions the sanctioning of Electronic 
Network, Inc. (``Electronic Network''), a company based in Montreal, 
Canada, which was added to the BIS Entity List on or about February 24, 
2023.\8\ Goltsev said, ``. . . do me a favor. If anyone ever asks about 
me, don't tell them who I am, where I am, etc. . . . Elnet's 
[Electronic Network] been in trouble for a long time because they 
exported a lot to Russia.'' Goltsev was an account manager and 
purchasing coordinator for Electronic Network.
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    \8\ See 88 FR 12170 (Feb. 27, 2023).
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    Communications between Goltsev and Zenchenko also reflect knowledge 
of and familiarity with U.S. export controls. Specifically, Goltsev 
also received requests from Zenchenko to obtain items on the CCL that 
were controlled for anti-terrorism reasons. For example, on or about 
December 16, 2022, in response to a query, Zenchenko advised Goltsev 
that ``76 pcs, you can buy them here with ECCN 3A991.c.3.'' In a 
message on or about February 1, 2023, Zenchenko asked Goltsev, ``ECCN: 
5A991.b.4 can you get this?'' and included a screenshot of a product 
from a Texas-based electronics distributor. Similarly, in a message on 
or about February 6, 2023, Zenchenko asked Goltsev, ``can you get this 
ECCN? 4A994.'' In a message on or about February 22, 2023, Zenchenko 
requested ``40 pcs ECCN 5A991.b.1 Can you get this?'' At the time of 
these communications, each of ECCNs listed in this paragraph required 
an export license to Russia and was subject to a presumption of denial 
licensing policy. See Section 746.8. Between November 2022 and February 
2023, SH Brothers made nine shipments to Zenchenko in Russia through a 
Turkish intermediary.

C. SH Brothers, SN Electronics, and Suntronic

    As alleged in the indictment and based on evidence presented by 
OEE, the co-conspirators used SH Brothers and SN Electronics to export 
items from the United States through intermediaries located in third 
countries. OEE has presented evidence that Nasriddinov founded SH 
Brothers on or about June 11, 2021 and SN Electronics, which was 
registered in his wife's name, on or about January 30, 2023. Both 
companies have listed addresses in Brooklyn, New York. One of 
intermediaries used for transshipment to Russia was Suntronic, a front 
company located in the U.A.E. and used by Bochkarev to conduct 
procurement operations for multiple Russian entities. As alleged in the 
indictment, on or about and between August 2022 and September 2023, SH 
Brothers exported more than 250 shipments of electronic components, 
valued at more than $7 million, to third-country transshipment 
companies, including Suntronic, where they were then unlawfully 
diverted to Russia.
    The indictment further alleges that, between in or about November 
2022 and August 2023, SH Brothers exported approximately 27 shipments, 
valued at approximately $1,086,058, to Suntronic. These shipments were 
then sent to Russian end users, including Petersburg Intelligent 
Transportation Logistics (``Petersburg''), which was added to OFAC's 
SDN list on or about May 19, 2023; Suntronic received approximately $15 
million from Petersburg between in or about October 2022 and February 
2023. As detailed in the indictment, one of the shipments, occurring in 
or about June 23, 2023, was for transceivers listed in Supp. No. 4 to 
Part 746 of the EAR and requiring a license to Russia, which carried a 
Tier 1 HTS code listed on the Common High Priority Items List. The 
transceivers, which have been found in Russian UAVs, required a license 
from BIS to be exported to Russia pursuant to section 746.5(a)(1) of 
the Regulations. These types of transceivers have been found in Russian 
unmanned aerial vehicles (``UAVs'') in Ukraine.
    Based on the facts set forth in the indictment, Goltsev and 
Bochkarev communicated about the shipments, including ways in which to 
conceal the ultimate destination and end users. For example, in a 
communication in or about January 2023, Goltsev informed Bochkarev that 
he needed an end user declaration and Bochkarev responded, ``darn.'' 
The two ultimately agreed to falsely list a U.A.E. company as the end 
user. In a February 2023 communication, Goltsev advised Bochkarev to 
``write something more substantial [to the U.S. company] so that there 
are no more questions.'' After Bochkarev asked, ``is it better to 
provide them with a Chinese end user,'' Goltsev stated ``yes should be 
ok.'' In another message on or about March 3, 2023, Bochkarev asked 
Goltsev about the possibility of making one shipment paid ``via the 
Chinese company,'' since ``each one separately so expensive, or does it 
mean extra trouble at customs?'' Goltsev responded, ``no sir, more than 
50-60 will trigger a lot of interest it's better to break it up.''
    The indictment also alleges that between in or about September 2022 
and November 2022, SH Brothers made approximately 15 shipments of 
electronic components, valued at approximately $352,000, to 
Testkomplekt through an intermediary located in Hong Kong. In or about 
November 2022, U.S. Customs and Border Protection (``CBP'') detained 
some shipments from SH Brothers that were allegedly bound for Hong Kong 
but ultimately destined for Testkomplekt in Russia. As detailed in the 
indictment, Chernikov repeatedly questioned Goltsev about the status of 
the detained shipments and provided him with false information to use 
in responding to CBP inquiries.
    Based on the facts alleged in the indictment and evidence presented 
by OEE, SH Brothers also made a shipment of microchips to Vetoshkina's 
company, Komtech, through a Turkish intermediary. Specifically, in a 
message on or about August 31, 2022, Komtech's founder and director 
requested that Vetoshkina procure 3,000 microchips made by an Arizona-
based manufacturer. Vetoshkina sourced the microchips through Goltsev 
and SH Brothers, who received several payments from the Turkish 
intermediary, including an October 3, 2022 payment for $5,300. The wire 
details for this payment listed the part number of the microchips and 
denoted ``QTY 2000.''
    In a message exchange on or about April 21, 2023, Vetoshkina and 
Goltsev discussed shipping the microchips through China or Turkey, 
ultimately deciding to make the shipment through Turkey to ``avoid 
problems.'' Goltsev provided Vetoshkina with an SH Brothers invoice for 
3,000 pieces of the requested microchip, which listed the applicable 
HTS codes and payment information for an SH Brothers bank account in 
Brooklyn, New York. On or about April 17, 2023, a U.S. company shipped 
a package containing the

[[Page 77958]]

microchips was mailed to SH Brothers and two days later, on or about 
April 25, 2023, Nasriddinov sent the same items to the intermediary in 
Turkey. OEE's evidence includes an invoice for 3,000 ATMEGA8A-MN 
Microchip Microcontrollers, and a second line item of 2,000 ATMEGA8A-MN 
Microchip Microcontrollers, bearing Tier 1 HTS code 8542310001, which 
is listed in Supp. No. 4 to Part 746 of the EAR and requires a license 
to Russia. The HTS code is listed on the Common High Priority Items 
List and the microchips would have required a license from BIS to be 
exported to Russia. See Section 746.5(a)(1)(ii).
    Based on OEE's investigation, which remains ongoing, SH Brothers 
also furthered the scheme by making false EEI filings, including by 
declaring that items were being shipped to one party when they were, in 
fact, being shipped to another, presumably to further obfuscate the 
transactions with respect to the ultimate destination and to evade 
detection by law enforcement. For example, OEE has presented evidence 
that, an EEI filing made by SH Brothers in or about February 16, 2023 
indicated that shipment was destined for China, with an intermediary 
consignee also located in China. Based on corresponding DHL records, 
however, the items were shipped to a different location in China not 
identified on the EEI. Records also reflect that the shipment contained 
items that would have required a license for export to Russia, 
specifically CY7C109D-10VXI Infineon SRAM Chips, bearing HTS code 
8542320041 and classified under ECCN 3A991.b.2.b.
    In another EEI filing made by SH Brothers on or about February 9, 
2023, ostensibly to the U.A.E, SH Brothers identified the intermediary 
consignee as Suntronic. Corresponding DHL records, however, show that 
SH Brothers shipped the items to a company located in Hong Kong. The 
shipment contained a ADM3202ARNZ AD Transmitter, bearing HTS code 
8542390001, a Tier 1 HTS code listed in Supp. No. 4 to Part 746 of the 
EAR, which would have required an export license for export to Russia 
pursuant to section 746.5(a)(1).
    OEE's investigation also indicates that, in or about January 2023, 
in a further effort to evade detection and in response to law 
enforcement scrutiny, including the delay or detention of several 
outbound shipments from SH Brothers, Goltsev and Nasriddinov began 
using SN Electronics to order and export electronic components. As 
alleged in the indictment, on or about and between November 8, 2022 and 
November 15, 2022, Goltsev and Nasriddinov exchanged a series of 
messages discussing a shipment of electronic components that had been 
detained by U.S. officials at John F. Kennedy International Airport 
(``JFK'') in Queens, New York. Goltsev commented that shipping to 
Russia had become ``dangerous'' and went on to say, ``we need to figure 
out why they keep holding the package . . . I don't really understand 
how they figured [it] out.'' In a subsequent message, on or about 
November 9, 2022, Goltsev commented that, ``in the future we will need 
to load from several companies, not to attract attention . . . for now 
large packages will be dangerous until we understand what they figured 
out . . . we will need to think of diversifying the load . . . so that 
not everything is moving from the same deck.''
    In subsequent communications between on or about January 31, 2023 
and February 10, 2023, Nasriddinov confirmed to Goltsev that the ``new 
company is already functioning . . . Its called SN Electronics'' and 
Goltsev responded, ``Wonderful sir . . . Eagerly waiting for Tax ID 
sir. We had problems with some large orders from [a Texas-based 
company] . . . we will reorder later from SN.'' Nasriddinov later 
provided Goltsev with SN Electronics' registered address in Brooklyn, 
New York, which was also the address of a restaurant that Nasriddinov 
owned.
    As detailed in the indictment, Goltsev and Nasriddinov then used SN 
Electronics to obtain approximately $36,871.49 worth of non-reflective 
switches, listed in Supp. No. 4 to Part 746 of the EAR and requiring a 
license to Russia, from a U.S. company for Chernikov and Testkomplekt. 
Although Nasriddinov had initially placed the order for these non-
reflective switches from the U.S. company through SH Brothers, the 
order was cancelled and the U.S. company told Goltsev that the 
``manufacturer requires that shipments of this product be direct to an 
END CUSTOMER from an AUTHORIZED DISTRIBUTOR only.''
    Goltsev subsequently placed the same order through SN Electronics, 
using the alias ``Gio Ross'' in his email communications with the U.S. 
company and falsely claimed in an email on or about February 15, 2023 
that SN Electronics was a ``prototype and design manufacturing 
company.'' On or about February 21, 2023, the order was shipped to an 
SN Electronics address in Brooklyn, New York and, on or about February 
27, 2023, Nasriddinov exported the items to a Hong-Kong based 
transshipment company frequently utilized by Testkomplekt. The switches 
had Tier 1 HTS codes that were included on the Common High Priority 
Items List and required a license from BIS to be exported to Russia 
pursuant to section 746.5(a)(1).

III. Findings

    I find that the evidence presented by BIS demonstrates that a 
violation of the Regulations by the above-captioned parties is imminent 
in both time and degree of likelihood. This includes evidence 
demonstrating the breadth of the conspiracy, that multiple parties and 
entities are involved, and that the conduct occurred over a lengthy 
period of time. As such, a TDO is needed to give notice to persons and 
companies in the United States and abroad that they should cease 
dealing with Nikolay Goltsev, Salimdzhon Nasriddinov, Kristina 
Puzyreva, Vladimir Bochkarev, Pavel Chernikov, Yekaterina Vetoshkina, 
Oleg Zenchenko, SH Brothers Group, Inc. (``SH Brothers''), SN 
Electronics, Inc. (``SN Electronics''), and Suntronic FZE 
(``Suntronic'') in export or reexport transactions involving items 
subject to the EAR. Such a TDO is consistent with the public interest 
to preclude future violations of the Regulations given the deliberate, 
covert, and determined nature of the misconduct and clear disregard for 
complying with U.S. export control laws.
    This Order is being issued on an ex parte basis without a hearing 
based upon BIS's showing of an imminent violation in accordance with 
section 766.24 of the Regulations.
    It is therefore ordered:
    First, that NIKOLAY GOLTSEV, a/k/a NICK STEVENS, a/k/a GIO ROSS, 
with an address at 107 Rue Caron, Ste-Anne-De-Bellevue, Quebec, Canada 
H9X4A1; SALIMDZHON NASRIDDINOV, with an address at 3734 Laurel Ave., 
Brooklyn, NY 11224; KRISTINA PUZYREVA, with an address at 107 Rue 
Caron, Ste-Anne-De-Bellevue, Quebec, Canada H9X4A1; VLADIMIR BOCHKAREV, 
with an address at Privolnaya Street 75, Korp.1, Apt. 173, Moscow, 
Russia; PAVEL CHERNIKOV, with an address at Zoologicheskiy Pereulok 9/
11. Apt.13, Moscow, Russia 123242; YEKATERINA VETOSHKINA, with an 
address at Ulitsa Privolnaya 75/1, Apt. 173, Moscow, Russia, 109431; 
OLEG ZENCHENKO, with an address at Vesenniya Street 16, Taytsy, 
Petersburg Region, Russia and an address at Kupchinskaya Street 29/1, 
Apt. 363, St. Petersburg, Russia 192283; SH BROTHERS GROUP, INC., with 
an address at 3734 Laurel Ave., Brooklyn, NY 11224; SN ELECTRONICS, 
INC., with an address at 2650 AB Coney

[[Page 77959]]

Island Ave, Brooklyn, NY 11223; and SUNTRONIC FZE, with an address at 
Shiekh Khalifa Bin Zayed St-Amberjem Tower E1/913 Ajman, United Arab 
Emirates; and when acting for or on their behalf, any successors or 
assigns, agents, or employees (each a ``Denied Person'' and 
collectively the ``Denied Persons'') may not, directly or indirectly, 
participate in any way in any transaction involving any commodity, 
software or technology (hereinafter collectively referred to as 
``item'') exported or to be exported from the United States that is 
subject to the EAR, or in any other activity subject to the EAR 
including, but not limited to:
    A. Applying for, obtaining, or using any license, License 
Exception, or export control document;
    B. Carrying on negotiations concerning, or ordering, buying, 
receiving, using, selling, delivering, storing, disposing of, 
forwarding, transporting, financing, or otherwise servicing in any way, 
any transaction involving any item exported or to be exported from the 
United States that is subject to the EAR, or in any other activity 
subject to the EAR; or
    C. Benefitting in any way from any transaction involving any item 
exported or to be exported from the United States that is subject to 
the EAR, or in any other activity subject to the EAR.
    Second, that no person may, directly or indirectly, do any of the 
following:
    A. Export or reexport to or on behalf of a Denied Person any item 
subject to the EAR;
    B. Take any action that facilitates the acquisition or attempted 
acquisition by a Denied Person of the ownership, possession, or control 
of any item subject to the EAR that has been or will be exported from 
the United States, including financing or other support activities 
related to a transaction whereby a Denied Person acquires or attempts 
to acquire such ownership, possession or control;
    C. Take any action to acquire from or to facilitate the acquisition 
or attempted acquisition from a Denied Person of any item subject to 
the EAR that has been exported from the United States;
    D. Obtain from a Denied Person in the United States any item 
subject to the EAR with knowledge or reason to know that the item will 
be, or is intended to be, exported from the United States; or
    E. Engage in any transaction to service any item subject to the EAR 
that has been or will be exported from the United States and which is 
owned, possessed or controlled by a Denied Person, or service any item, 
of whatever origin, that is owned, possessed or controlled by a Denied 
Person if such service involves the use of any item subject to the EAR 
that has been or will be exported from the United States. For purposes 
of this paragraph, servicing means installation, maintenance, repair, 
modification or testing.
    Third, that, after notice and opportunity for comment as provided 
in section 766.23 of the EAR, any other person, firm, corporation, or 
business organization related to Nikolay Goltsev, Salimdzhon 
Nasriddinov, Kristina Puzyreva, Vladimir Bochkarev, Pavel Chernikov, 
Yekaterina Vetoshkina, Oleg Zenchenko, SH Brothers Group, Inc., SN 
Electronics, Inc., and Suntronic FZE by affiliation, ownership, 
control, or position of responsibility in the conduct of trade or 
related services may also be made subject to the provisions of this 
Order.
    In accordance with the provisions of section 766.24(e) of the EAR, 
Nikolay Goltsev, Salimdzhon Nasriddinov, Kristina Puzyreva, Vladimir 
Bochkarev, Pavel Chernikov, Yekaterina Vetoshkina, Oleg Zenchenko, SH 
Brothers Group, Inc., SN Electronics, Inc., and Suntronic FZE may, at 
any time, appeal this Order by filing a full written statement in 
support of the appeal with the Office of the Administrative Law Judge, 
U.S. Coast Guard ALJ Docketing Center, 40 South Gay Street, Baltimore, 
Maryland 21202-4022.
    In accordance with the provisions of section 766.24(d) of the EAR, 
BIS may seek renewal of this Order by filing a written request not 
later than 20 days before the expiration date. Respondents Nikolay 
Goltsev, Salimdzhon Nasriddinov, Kristina Puzyreva, Vladimir Bochkarev, 
Pavel Chernikov, Yekaterina Vetoshkina, Oleg Zenchenko, SH Brothers 
Group, Inc., SN Electronics, Inc., and Suntronic FZE may oppose a 
request to renew this Order by filing a written submission with the 
Assistant Secretary for Export Enforcement, which must be received not 
later than seven days before the expiration date of the Order.
    A copy of this Order shall be served on each denied person and 
shall be published in the Federal Register.
    This Order is effective immediately and shall remain in effect for 
180 days.

Matthew S. Axelrod,
Assistant Secretary of Commerce for Export Enforcement.
[FR Doc. 2023-25005 Filed 11-13-23; 8:45 am]
BILLING CODE 3510-DT-P