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Defendant Participated in Overseas Illicit Procurement Network That, After Russia’s Invasion of Ukraine, Illegally Procured Large Quantities of Dual-Use, Military Grade Organic Light-Emitting Diode (OLED) Micro-Displays for Russian End-Users

March 4, 2024 - Maxim Marchenko, 51, a Russian citizen who has resided in Hong Kong, pled guilty on Thursday, February US DOJ29, 2024, to charges of money laundering and smuggling goods from the United States. Marchenko was arrested in September 2023.

According to court documents, Marchenko operated several Hong Kong-based shell companies, including Alice Components Co. Ltd. (Alice Components), Neway Technologies Limited (Neway) and RG Solutions Limited (RG Solutions). Marchenko and two co-conspirators (CC-1 and CC-2), who are also Russian nationals, operate an illicit procurement network in Russia, Hong Kong, and elsewhere overseas. This procurement network has fraudulently obtained from U.S. distributors large quantities of dual-use, military grade microelectronics, specifically OLED micro-displays, on behalf of Russia-based end users. To carry out this scheme, Marchenko, CC-1, and CC-2 used shell companies based in Hong Kong and other deceptive means to conceal from U.S. Government agencies and U.S. distributors that the OLED micro-displays were destined for Russia. The technology that Marchenko and his co-conspirators fraudulently procured have significant military applications, such as in rifle scopes, night-vision googles, thermal optics and other weapon systems.

“By his own admission, Mr. Marchenko conspired to smuggle military-grade technology to Russia, using a complex network of front companies to hide his illicit activity,” said Assistant Attorney General Matthew G. Olsen of the Justice Department’s National Security Division. “Today, once again, the Justice Department is holding accountable those who would enable the Kremlin and its unjust war of aggression against Ukraine.” 

“Today, Maxim Marchenko admitted in court that he illicitly sought to procure U.S.-manufactured, military grade microelectronics to deliver to end users in Russia,” said U.S. Attorney Damian Williams for the Southern District of New York. “Marchenko concealed his scheme to funnel these microelectronics – which had application for use in rifle scopes, night-vision goggles, thermal optics and other weapons systems – by using shell companies and other elaborate money laundering techniques. Today’s guilty plea should send a strong message to those who attempt to break the law by supplying Russia with U.S. military technology that this office will vigorously pursue such smuggling schemes and hold those involved to full account.”

“Today’s guilty plea demonstrates the FBI’s relentless pursuit of justice as we put yet another individual who tried to illegally transport military-grade U.S. technology to Russia behind bars,” said Executive Assistant Director of the FBI's National Security Branch Larissa L. Knapp. “We will continue to collaborate with our partners to protect our national security and prevent the smuggling of such goods which could benefit authoritarian adversaries.”

“The Russian military relies on illicit procurement networks, including the one Marchenko operated here, to perpetrate their brutal war against the Ukrainian people,” said Matthew Axelrod, Assistant Secretary of Commerce for Export Enforcement. “We will continue to leverage all of our authorities to combat the transshipment of U.S. parts through third countries, like the People’s Republic of China, to the Russian military.”

To perpetrate the scheme, Marchenko and other members of the conspiracy acquired the dual-use OLED micro-displays from U.S.-based distributors using Marchenko’s Hong Kong-based shell companies, including Alice Components, Neway and RG Solutions. Members of the conspiracy, including Marchenko, procured these sensitive microelectronics by falsely representing to the U.S. distributors (who, in turn, are required to report to U.S. agencies) that Alice Components was sending the shipments to end users located in China, Hong Kong and other countries outside of Russia for use in electron microscopes for medical research. In reality, the OLED micro-displays were destined for end users in Russia. Marchenko and other members of the conspiracy concealed the true final destination (Russia) from U.S. distributors for the purpose of causing false statements to the U.S. agencies.

To conceal the fact that these OLED micro-displays were destined for Russia, Marchenko and other members of the conspiracy worked together to transship the illicitly procured OLED micro-displays by using pass-through entities principally operated by Marchenko in third countries, such as Hong Kong. Marchenko then caused the OLED micro-displays to be shipped to the ultimate destination in Russia using, among other entities, a freight forwarder known to provide freight forwarding services to Russia. In addition, Marchenko and other members of the conspiracy used Hong Kong-based shell companies, principally operated by Marchenko, to conceal the fact that payments for the OLED micro-displays were coming from Russia. In total, between in or about May 2022 and in or about August 2023, Marchenko’s shell companies funneled a total of more than $1.6 million to the United States in support of the procurement network’s efforts to smuggle the OLED micro-displays to Russia.

Marchenko pleaded guilty to one count of money laundering, which carries a maximum penalty of 20 years in prison, and one count of smuggling goods from the United States which carries a maximum penalty of up to 10 years in prison. He is scheduled to be sentenced on May 29 in Manhattan. A federal district court judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.

The FBI and Commerce Department’s Bureau of Industry and Security are investigating the case. 

Assistant U.S. Attorneys Jennifer N. Ong and Shiva H. Logarajah for the Southern District of New York are in charge of the prosecution, with assistance from Trial Attorney Garrett Coyle of the Counterintelligence and Export Control Section.

Thursday’s actions were coordinated through the Justice Department’s Task Force KleptoCapture and the Justice and Commerce Departments’ Disruptive Technology Strike Force. Task Force KleptoCapture is an interagency law enforcement task force dedicated to enforcing the sweeping sanctions, export restrictions and economic countermeasures that the United States has imposed, along with its allies and partners, in response to Russia’s unprovoked military invasion of Ukraine. The Disruptive Technology Strike Force is an interagency law enforcement strike force co-led by the Departments of Justice and Commerce designed to target illicit actors, protect supply chains, and prevent critical technology from being acquired by authoritarian regimes and hostile nation states.

Source: DOJ Release