In the latest round of sanctions imposed by the United States against companies and individuals supporting Russia’s invasion of Ukraine, about 20 out of nearly 300 companies targeted are from China and Hong Kong. Most of the sanctioned Hong Kong companies are involved in providing electronic products for manufacturing weapons to Russia. Among them, Pixel Devices company is known to be the highest-profile as Russia’s electronic procurement network in Hong Kong, having exported electronic products worth over $210 million to Russia over the past two years.
On May 1st, the U.S. Department of the Treasury announced a new round of sanctions targeting nearly 200 entities, while the State Department simultaneously issued sanctions on 80 targets, including 60 companies from Russia, Azerbaijan, Belgium, Turkey, the United Arab Emirates, as well as 12 Chinese companies and 8 from Hong Kong.
The Treasury Department stated that the U.S. will take further multilateral actions to weaken Russia’s capacity to sustain its war machinery, limit the Kremlin’s revenue streams, and prevent illegal means of obtaining necessary supplies for the war in Ukraine. The sanctions will target Russia’s military-industrial facilities, chemical and biological weapons programs, as well as companies and individuals in third countries assisting Russia in obtaining key materials for weapons or defense-related production.
The Treasury Department specifically mentioned entities in China and other third countries, stating that these entities provide key materials to Russia’s military-industrial base, enabling Russia to continue its aggression towards Ukraine and posing a serious threat to international security.
Hong Kong is not exempt from U.S. scrutiny under the so-called “One Country, Two Systems” principle. In December last year, the U.S. House of Representatives passed the National Defense Authorization Act, listing both Hong Kong and China (the CCP) as “Foreign Adversaries,” alongside North Korea, Cuba, Iran, and Venezuela.
According to documents released by the U.S. Department of the Treasury, three Hong Kong companies were involved in procuring drones for Russia.
One company named Tulun International Holding Limited, based in Hong Kong, acts as a procurement intermediary. The Treasury Department stated that the company claimed to be an end-user of global navigation satellite systems (GNSS), but actually resold electronic boards from the system, which were ultimately installed by the Russian military on one-way attack drones targeting Ukraine.
Documents from the Treasury Department revealed that Tulun International is located at Room B, 9th Floor, Tang Shun Commercial Building, Wan Chai, Hong Kong, and faces secondary sanctions risks for its operations in specific sectors within the Russian Federation supporting Russia’s military-industrial base.
Furthermore, RG Solutions Limited, a Hong Kong company associated with Ultran Electronic Components (Ultran EK) based in Russia, was also singled out by the Treasury Department.
Ultran EK is responsible for procuring microelectronic components, including parts retrieved from Orlan-10 drones used against the Ukrainian military. Between June 8, 2022, and September 26, 2023, Ultran EK imported 71 batches of electronic integrated circuits to Russia, which included field-programmable gate arrays (FPGA) for drone applications.
Following Russia’s full-scale invasion of Ukraine in February 2022, Ultran EK turned to RG Solutions for microelectronic components. From January 1 to December 25, 2023, RG Solutions exported 104 batches of electronic integrated circuits, revealing its involvement in trading military electronic components with Russia through transactions related to funds, invoices, transport services, integrated circuits, compressor spare parts, freight, and contract signing.
According to relevant executive orders, RG Solutions also faces secondary sanctions risks for its operational activities supporting Russia’s military-industrial base and has been designated for sanctions.
RG Solutions, established on July 2, 2014, is located at Room 606, 6th Floor, Celebrity Commercial Centre, Sham Shui Po, Kowloon, Hong Kong, with commercial registration numbers 2115045 and 63526362 [RUSSIA-EO14024].
The U.S. Department of Justice indicated that RG Solutions, a shell company set up by a Russian man Maxim Marchenko, who resided in Hong Kong, was indicted last year by the U.S. Department of Justice for smuggling large quantities of U.S.-made electronic products to Russia.
Additionally, Finder Technology Limited, a Hong Kong company, exported 293 batches of electronic integrated circuits, including circuits suitable for drones, between January 3 and December 29, 2023.
The Treasury Department indicated that Finder Technology Limited acted as an intermediary for Joint Stock Company Compel (Compel) in Russia, even after Compel was designated by the U.S. Treasury Department on July 20, 2023, under Executive Order 14024 as operating or having operated in the electronic sector of the Russian Federation’s economy.
According to documents, Finder Technology Limited is located at Unit A, 7th Floor, Yeung Yiu Chung Industrial Building, Fung Yip Street, Chai Wan, Hong Kong, and faces secondary sanctions risks according to the related executive order.
Finder Technology Limited, registered on April 4, 2005, has commercial registration numbers 960469 and 35585540 [RUSSIA-EO14024].
The Treasury Department has identified four Hong Kong companies as suppliers of technology to Russia.
HK Hengbangwei Electronics Limited was accused of separately exporting hundreds of batches of foreign-origin microelectronic products along with Chip Space Electronics Co., Limited to Russia, including to Uniservice, a Russian tech company subjected to U.S. sanctions.
Chip Space Electronics Co., Limited’s official website is www.chipspace-elec.com, and the company faces secondary sanctions risks for its operations in specific sectors within the Russian Federation supporting Russia’s military-industrial base, according to Executive Orders 14024 and 14114.
Documents indicate that Chip Space Electronics was established on November 21, 2022, with company registration number 3210227 [RUSSIA-EO14024].
On the other hand, HK Hengbangwei Electronics Limited, registered on June 13, 2022, is located at Room 02, 21st Floor, Ocean Building, Pitt Street, Yau Ma Tei, Kowloon, with company registration number 3162098 [RUSSIA-EO14024].
IPM Limited (also known as B&W CONSULTING), another Hong Kong company, was accused of exporting hundreds of batches of foreign-origin microelectronic products to Uniservice and machine tool components to Russia.
IPM is situated at Room A, 6th Floor, Regent Centre, 122 Austin Road, Tsim Sha Tsui, Hong Kong, with offices in Austria, and the company also faces secondary sanctions risks.
Established on November 23, 2012, IPM has registration number 1829992 [RUSSIA-EO14024].
Jinmingsheng Technology HK Co Limited was cited for supplying LLC Onelek, a Russian electronic component supplier under U.S. sanctions, with noise filters, pressure sensors, and microcontrollers for Russia’s missile systems and drones.
Jinmingsheng’s addresses are Room 1838, Guoli Building, Zhonghang Road, Futian District, Shenzhen, Guangdong, China, and Room 61868, 6th Floor, High-Tech Trade Center, 163 Zhenhua Road, Futian District, Shenzhen, Guangdong, China 518031, with an office in Hong Kong.
Jinmingsheng, established on December 9, 2008, has registration number 1292952 and commercial registration number 50093445 [RUSSIA-EO14024].
According to the Treasury Department, Compliga, headquartered in Russia, is a supplier of IT, equipment, and electronic products. Since April 1, 2022, Compliga has imported electronic products worth at least $180 million from abroad, with the majority coming from Pixel Devices Limited, based in Hong Kong. Pixel’s main client is Compliga, and since April 1, 2022, Pixel has shipped at least $210 million worth of electronic products to Russia.
Under U.S. Executive Order 14024, Compliga, Pixel, and an intermediary company Carovilli based in Slovakia were named for engaging or having engaged in the technical department of the Russian Federation’s economy.
Pixel Devices Limited, located at 16th Floor, New Hennessy Building, 263 Hennessy Road, Wan Chai, Hong Kong, offers components and sub-assemblies to enterprises in various industries, including military and aerospace.
Pixel’s Hong Kong identification number is 2569276, with another Hong Kong identification number 68097456 [RUSSIA-EO14024].