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On June 21, 2024, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) designated 12 Kaspersky Lab executives and senior leaders under Executive Order 14024. The action blocks their covered property within U.S. jurisdiction; Treasury explicitly said it did not designate Kaspersky Lab, its parent or subsidiaries, or the company’s CEO. A separate Commerce Department action restricted certain Kaspersky software transactions with U.S. persons.
Who are the 12 Kaspersky executives sanctioned by the U.S.?
Treasury said the 12 people were designated for operating or having operated in the technology sector of the Russian Federation economy. The roles below are those Treasury described in its June 21, 2024 announcement. Treasury’s announcement names them as follows:
- Andrei Gennadyevich Tikhonov — Chief Operating Officer; also described as a member of boards 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.
What does an OFAC designation mean?
For each designated person, Treasury says property and interests in property that are 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 under E.O. 14024; it should not be described as a Treasury designation of the company.
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Treasury explicitly stated that OFAC did not designate Kaspersky Lab itself, its parent or subsidiary companies, or its CEO. That distinction matters: the names in the Treasury action are individuals, and the blocking consequences described by Treasury apply to their covered property and interests in property.
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The State Department’s contemporaneous explanation said the U.S. government was concerned about Kaspersky’s privileged access to files and computers and the possibility of Russian government exploitation. That is the government’s stated rationale, not independent proof that Kaspersky misused customer data. The State Department’s explanation describes that concern.
How was the Treasury action different from the Kaspersky software restrictions?
The Treasury designation and the Commerce Department’s software restrictions were separate actions, announced on different dates under different authorities. Treasury designated 12 people on June 21, 2024, under E.O. 14024. Commerce announced its final determination on June 20, 2024, under E.O. 13873, restricting specified transactions involving Kaspersky cybersecurity and antivirus products or services with U.S. persons. Commerce also added AO Kaspersky Lab, OOO Kaspersky Group, and Kaspersky Labs Limited to the Entity List. BIS’s announcement and its Kaspersky action page explain the determination and related measures.
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| Action | Agency and authority | Target | Effect described by the government |
|---|---|---|---|
| Treasury designations, June 21, 2024 | Treasury/OFAC, E.O. 14024 | 12 named Kaspersky executives and senior leaders | Covered property and interests in property of designated persons are blocked and must be reported to OFAC. |
| Commerce determination, June 20, 2024 | Commerce/BIS, E.O. 13873 | Specified transactions involving Kaspersky cybersecurity and antivirus products or services with U.S. persons; three Kaspersky-related entities were separately added to the Entity List | Restrictions apply to the covered transactions, as defined in the determination; this is not the same action as OFAC’s individual designations. |
What did the Commerce determination mean for existing users?
BIS allowed some existing operations, including antivirus signature and codebase updates, during a transition period that ended at 12:00 a.m. EDT on September 29, 2024. The action page also describes exceptions for specified threat-intelligence, security-training, and purely informational or educational consulting and advisory services. These were details of the Commerce determination, not exceptions to Treasury’s designations.
Commerce urged individuals and businesses using Kaspersky software to transition to new vendors. It said users would not face legal penalties under the determination simply for continuing to use existing Kaspersky products and services, while warning that continued use carried cybersecurity and associated risks. Those statements describe Commerce’s published position and are not legal advice about a particular person’s transactions.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How to check current sanctions or restriction status
The June 2024 announcements establish what the government did then; they do not establish each person’s status in October 2026. OFAC’s June 21 notice records the SDN List update, but list status can change. Before making a current compliance decision, check each name against OFAC’s Sanctions List Search and consult current BIS guidance for the software determination. For decisions about a specific transaction, seek qualified legal advice.
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