Adata Technology X 3Logic Group: Bypassing Sanctions from Taiwan to Moscow

Is there a better way to start 2026 than reading UnderYourNoZ’s latest OSINT investigation? We don’t think so!
The UnderYourNoZ team wishes you a very happy new year, full of OSINT investigations exposing complex schemes built by Russia to circumvent international sanctions! We are also thrilled to announce the launch of our brand-new website! You’ll find there all of previous investigations, and more to come!

Adata, a Taiwanese company in the eye of the Russian storm

First, let’s introduce our culprit of the day: the Taiwanese company Adata Technology. Based in Taipei, it has two legal addresses registered. The first one is 18F, №258, Lian Cheng Rd., Chung Ho Cityu, Taipei, and the other one is 25F, №533, Tanmei St Neihu Dist, Taipei.
Adata claims as the second world manufacturer of DRAM (which stands for Dynamic random-access memory), memory modules, and electronics. To be short, the company produces and sells electronic components you could use for your computers or…your weapons. Founded in 2001, Adata currently employs a few thousands of people according to open sources . Yeah, that’s a huge range but we didn’t manage to reduce the scope with online information.

Source: https://www.adata.com

Source: https://ar.linkedin.com/company/adata-technology

Why is Adata so interesting? Though it’s not a sanctioned company, their clients are! UnderYourNoZ gained access to exclusive documents thanks to a very-well informed individual — we’ll call him Truffle — proving Adata’s strong ties to Russian sanctioned entities involved in Russia’s war industry and the bloodshed it is causing in Ukraine.

From Adata Technology to 3Logic Group

We warmed up by introducing Adata, now let’s focus on its Russian BFF and favorite partner in crime 3Logic Group (INN 7724338125). Based in Moscow at Kagatinskya D6 Str 9 Com 15 Office 5, and also known as NEW AI IT PROJECT, 3Logic develops and produces hardware and computer components. Owned and managed by sanctioned Alexander Alexandrovich Bashlykov, it would employ around 1 500 people.

Source: http://www.3l.ru

3Logic Group is sanctioned by the OFAC since September 2023. Its CEO is sanctioned too. One might argue that Taiwan has not officially engage in the enforcement of multilateral sanctions against Russia. However, unilateral measures have been adopted. Since 2022, Taiwan has tightened its restrictions on exports of semiconductors, sensitive technologies, and dual-use goods to Russia.

Back to our main concern: sheer links between Adata Technology and 3Logic Group! Remember our investigation on Chimmed and Rusmedtorg? The same process applies here according to emails we got access to. In order to avoid selling goods to a sanctioned entity, Adata sends its production to a shell company named Yanda Technology, acting as a cover.

Let’s meet Evgenii Belenok from Adata Technology (user of the mail address evgenii_belenok@adata.com) and Milena Gasan-Djalalian, coordinator of 3Logic’s purchasing department (m.gasandjalalian@3l.ru). Their record shows they exchange on a regular basis.

In an email to Milena Gasan-Djalalian, Evgenii Belenok explicitly mentions a payment through the Chinese shell company Yanda Technology to keep the business afloat. Belenok implies that a former company named Tready has stopped to be efficient to hide their malicious activities.

Translation:
Milena, hello!
I ask you to help order the samples below for comments to our PR agency will it be possible to deliver this Wednesday around noon? Now that we are paying through Yanda, Tready is no longer relevant.

Source: https://www.facebook.com/r.vitvitski

We dug in a little bit to learn more about the people linked to the email addresses doing the shady business for Adata. We found two social media accounts matching the names of these people.
One is revealing and is probably misleading. Dead ends happen in the OSINT world!

There’s a LinkedIn account belonging to a “Evegnii Belenok” who did work in Taiwan and ranks Adata Technology’s LinkedIn business page among his interests. Though it doesn’t specify he actually works for Adata, one might properly assume we spotted the right guy. Among other things, we learnt Evegnii studied at the Taiwanese Ming Chuan University (hence working for a Taiwanese company afterwards?) and might be from Kazakhstan (like so many individuals helping Russia, see our investigation on KazUAV).

Source: https://www.linkedin.com/in/evgenii-belenok-4a4483b9/

We found a Facebook account belonging to Milena Djalalyan (not the same writing) but failed to find conclusive evidence this might match our lady!

Source: https://web.archive.org/web/20250420101336/http://kazuav.kz/

Why is this wrong? Dual-use goods to the Russian army

Through Truffle, we also gained access to invoices from Adata to Yanda concerning external HDD. At first sight, the invoices only seem to concern random electronic components. But for a careful reader, it illustrates how Adata and 3Logic Group are circumventing sanctions through Yanda.

Adata Technology produces merchandise listed as high priority items concerned by HS codes. HS for Harmonized System codes for goods classification, a list which allows to identify high-tech dual-use (i.e. civilian and military grade) items. These dual-use assets, such as the external HDD, might be diverted from their original purpose and employ as component in military products.

ООО НОВЫЙ АЙ ТИ ПРОЕКТ / 3Logic Source: ImportGenius

For instance, an external HD is listed in the critical goods list from the US and the EU, under the HS code 8471.70. The EU Regulation №2024/745 prohibits and sanctions the export, sale and transfer of dual- use and high-tech goods from the critical goods list, that might be use by the Russian army on the battlefield in Ukraine.

Details on the HS code 847170

Invoice from Adata to Yanda about external HDD

A proxy out of many: Yanda was not the first!

Fruitful deals between Adata and 3Logic Group isn’t new business, the two companies are linked for a few years now, and Yanda is not their first try at it! The use of a third-party company for payments lasts since… October 2023!

Remember that 3Logic Group is sanctioned since September 2023. It did not take them very long to find a loophole to keep its business running despite U.S. sanctions. The data provided by our whistleblower helped us understand and illustrate this. On October 2023, Adata Technology and 3Logic Group signed an additional deal to their distributorship agreement, allowing “payment for the goods to be made by third-parties”. This contract below concerned the use of Russian import and export firm AB-Trade LLC.

After AB-Trade LLC and before Yanda, Adata and 3Logic Group also worked with Tready Co. — FZCO, a company based in Dubai (Dubai Silicom Oasis, DDP, Building A1, Dubai). This firm was mentioned in the mail exchange between Evgenii (Adata) and Milena (3Logic Group) as “not relevant” anymore. It was specialized in the trade of computers, servers, printing equipment but also medical device and — main interest for Adata-3Logic — was not sanctioned…yet! It appears though the Russians stopped this partnership quite recently in favor of the Chinese one.

Further proof of the use of Tready as proxy to avoid sanctions, we got access to an invoice from Adata to Tready dated from the beginning of 2024. Here, an external HDD , HS code 8471.70 (external storage units with magnetic disks) and which is included in the list of critical assets of the EU regulation.

Repeating the same pattern, again and again

In addition of Yanda and AB-Trade LLC, we accessed other documents from Adata assessing the company is repeating the same scheme with many other sanctioned companies in total impunity. An e-mail exchange between the lovely Mandy Fu from Adata to the delightful Tabula Egor from the Russian sanctioned company OCS Distribution mentions a payment through two Serbian firms Avala Informatikaand Soha Info (Soha is sanctioned since October 2022).

(email exchange between Adata and OCS)

(Payment from Soha to Adata)

Invoice from Adata to Avala Informatika

Source: https://avalainformatika.rs/

We easily found Mandy Fu’s LinkedIn profile, who seems to be remarkably open about her focus on Russian products!

Source: https://www.linkedin.com/in/%E6%80%A1%E7%92%87-%E5%82%85-8b28801b6/

Source: https://www.instagram.com/garkovna/

Getting into the details of the list, it’s frankly amazing to discover several sanctioned Russian companies among the Adata’s clients such as OCS (mentioned earlier) or Aquarius (sanctioned by the OFAC since September 2022) in addition to 3Logic.

Source: https://www.opensanctions.org/entities/NK-mKZmWcrS8TSkuHmCNZeEHg/

Source: https://www.facebook.com/elena.gnetova

NOW WHAT?

Like in every OSINT investigation we released for the past year, we all wonder: how is this kind of scheme still happening and why do these companies suffering international sanctions keep buying products they shouldn’t be allowed to?

Let’s be honest, we are sometimes a little bit depressed when we discover that another Russian company found out a new way to circumvent sanctions, but it also gets us a new motivation to take them down! We do believe this isn’t a pointless fight.

With curiosity, OSINT tools and a little help (huge thanks to the vigilant citizens who risk sharing sensitive material with us), the UnderYourNoZ team is always very proud to expose the malign actions of Russian companies and their allies!

If you want to help us like others did, or just read or previous work and our next investigations, join us on Discord, follow our X and Bluesky accounts and share our content!

You can also write your story, share tips and leads at underyournoz@protonmail.com, so that no Russian warmonger can hide UnderYourNoZ anymore!

 

 Table of contents

> Adata, a Taiwanese company
> 3Logic Group 
> Dual-use goods to the Russian army
> A proxy out of many
> A repeating pattern 
> Now what?