The US designated 4 companies and individuals for assisting Divetechnoservices, a Russian sanctioned entity, to evade sanctions. The companies and individuals provided a number of services to Divetechnoservices. The sanctioned individuals and entities are:  

Vela-Marine Ltd.

Marina Igorevna Tsareva 

Anton Aleksandrovich Nagibin

Lacno S.R.O. 

Lacno was sanctioned for attempting to facilitate a payment of $20,000 on behalf of Divetechnoservices. 

Analysis: When one company is sanctioned, similar activities that the sanctioned company was undertaking are frequently ‘spun out’ to other companies in an effort to circumvent sanctions. In the case of Russia, this may be particularly true as Russia spent decades developing a “complex and resilient” network to raise, transfer, hide, and obscure the origin and movement of funds generated through illicit activity including sanctions evasion.

This can create significantly more work for individuals attempting to evade sanctions, but also for those trying to implement the sanctions as they must identify all the new entities involved in the previous activity. Rarely do sanctioned entities cease their activities altogether.