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4/15/2024

Treasury Targets Belarusian Sanctions Evasion Networks and Cogs in Russia’s War Machine | U.S. Department of the T…

Treasury Targets Belarusian Sanctions Evasion Networks and
Cogs in Russia’s War Machine
April 15, 2024

WASHINGTON — Today, the U.S. Department of the Treasuryʼs O ice of Foreign Assets
Control (OFAC) is designating 12 entities and 10 individuals pursuant to Executive Order (E.O.)
14038. This action builds on U.S. sanctions imposed in response to Belarusʼs fraudulent
August 2020 election, as well as President Alyaksandr Lukashenkaʼs (Lukashenka) support for
Russiaʼs illegal full-scale invasion of Ukraine. Todayʼs action sustains U.S. financial pressure on
the Lukashenka regime for its continuing support for Russiaʼs war against Ukraine and the
financial benefit it derives from this activity.
The individuals and entities OFAC is targeting today include six revenue-generating stateowned enterprises (SOEs) and one entity and five individuals involved in facilitating
transactions for a U.S.-designated major Belarusian defense sector enterprise. OFAC is
additionally targeting five entities and five individuals involved in a global arms network doing
business with a U.S.-designated Belarusian defense firm.
“The authoritarian Lukashenka regime continues to rely on revenue from its SOEs to fund its
violent suppression of its citizens and to circumvent U.S. sanctions,” said Under Secretary of
the Treasury for Terrorism and Financial Intelligence, Brian E. Nelson. “We will continue to
leverage our broad suite of tools to target Belarusʼs extensive illicit facilitation networks and
hold the regime accountable for its complicity in, and profiteering from, Russiaʼs unjust war in
Ukraine.”
Included in todayʼs designations is a coordinated action with the Department of Justice and
Federal Bureau of Investigation. Concurrent with todayʼs actions by Treasury, the Department
of Justice charged two principals of the now-designated Iraq-based arms company Black
Shield Company for General Trading LLC, the now-designated Mohamad Deiry and Samer
Rayya, with conspiring to unlawfully export weapons and ammunition from the United States
to Sudan. The case was unsealed today in the Southern District of Florida. Deiry and Rayya
remain at large and wanted by the Federal Bureau of Investigation.

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Todayʼs designations also coincide with a separate sanctions action against Belarus by the
Government of Canada. This coordination is demonstrative of the sustained commitment
amongst partners to amplify the Lukashenka regimeʼs continued anti-democratic governance
in Belarus.

REVENUE GENERAT ING STAT E-OW NED ENT ERPRISES
OJSC Stankogomel (Stankogomel) is a machine tool building SOE based in Gomel, Belarus
that regularly collaborates across various Belarusian and Russian industries. In 2023,
Stankogomel signed contracts with U.S.-designated Russian defense firms Kalashnikov
Concern and Almaz-Antey to provide material support to their operations.
OFAC is designating Stankogomel pursuant to E.O. 14038 for being owned or controlled by
the Government of Belarus (GoB).
OJSC AGAT-Control Systems-Managing Company of Geoinformation Control Systems
Holding (AGAT) is an SOE that sells control systems for the Belarusian Armed Forces,
industrial computers, navigation, and video surveillance systems. It is one of the largest
enterprises of State Authority for Military Industry of the Republic of Belarus (SAMI)—
designated by OFAC on February 24, 2022, pursuant to E.O. 14038 for being a political
subdivision, agency, or instrumentality of the GoB—and had an operating revenue of
$40 million in 2022. AGAT is licensed to conduct foreign trade activities in relation to special
goods, holding patents in Belarus, the Russian Federation, and the Eurasian Patent
Organization. AGAT is listed on the U.S. Department of Commerce Bureau of Industry and
Securityʼs Entity List and was designated by Canada for a grave breach of international peace
and security.
OFAC is designating AGAT pursuant to E.O. 14038 for being owned or controlled by the GoB.
AGAT is the management company for four additional entities located in Belarus that OFAC is
also designating: JSC NIIEVM, JSC Communication Equipment, JSC AGAT-System, and LLC
InnoTech Solutions.
JSC NIIEVM is a developer and producer of dual-use computer equipment and specializes
in the modernization and repair of weapons systems and military and special equipment.
In cooperation with SAMI and partner enterprises in Russia, JSC NIIEVM is involved in air
defense radio-technical facilities, air defense missile systems, mobile systems of
electromagnetic warfare, reconnaissance control, and radio jamming systems.
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JSC Communication Equipment specializes in the production of modern radio
communication and telecommunication equipment, including products for uniformed
services, and HF and VHF transceivers for civil and military use.
JSC AGAT-System is a leading organization for creation and development of means of
special radio and wired communication in the Belarusian market. JSC AGAT-System is
listed on the U.S. Department of Commerce Bureau of Industry and Securityʼs Entity List
and was designated by Canada for a grave breach of international peace and security.
LLC InnoTech Solutions is a so ware development company with a special permit from
the GoB for technical and/or cryptographic information protection and design, creation,
and audit of information security systems of critical informatization objects. LLC InnoTech
Solutionsʼ operating revenue was $6.51 million in 2022.
OFAC is designating JSC NIIEVM, JSC Communication Equipment, JSC AGAT-System, and LLC
InnoTech Solutions pursuant to E.O. 14038 for being owned or controlled by, or having acted
or purported to act for or on behalf of, directly or indirectly, AGAT, a person whose property
and interests are blocked pursuant to E.O. 14038. OFAC previously designated AGAT subsidiary
AGAT Electromechanical Plant OJSC on December 2, 2021, pursuant to E.O. 14308 for being
owned or controlled by, or having acted for or on behalf of, directly or indirectly, the GoB.

PELENG FACILITAT ION NET W ORK
U.S.-designated Belarusian SOE Peleng JSC (Peleng) is a leading design enterprise in the
Belarusian optoelectronic industry and is one of Russiaʼs most important industrial suppliers
in Belarus. OFAC designated Peleng on December 2, 2021, pursuant to E.O. 14038 for
operating or having operated in the defense and related materiel sector of the economy of
Belarus and for operating or having operated in the security sector of the economy of
Belarus. Peleng is the exclusive supplier of fire-control systems for major lines of Russian
tanks and is a developer of sights with thermal imagers. Peleng produces sights for BTR-82A
military vehicles and supplies airfield automated meteorological systems and, in partnership
with U.S.- designated Russian defense entity Joint Stock Company All-Russian Research
Institute Signal (Signal), will be engaged in the production of a complex for artillery units. On
June 28, 2022, the Department of State designated Signal pursuant to E.O. 14024 for
operating or having operated in the defense and related materiel sector of the Russian
Federation economy.

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Shenzhen 5G High-Tech Innovation Co., Limited (Shenzhen 5G) is a Peopleʼs Republic of
China (PRC)-based entity that serves as an intermediary for Peleng. Shenzhen 5G and Peleng
operate under a framework agreement that authorizes Shenzhen 5G to engage with Chinese
manufacturing entities on Pelengʼs behalf. Peleng tasks Shenzen 5G with soliciting proposals
for the specifications and quantities of various components, which are ultimately sourced to
Peleng. Shenzhen 5G oversees the relationship with the manufacturer and coordinates the
final delivery of goods to Peleng.
OFAC is designating Shenzhen 5G pursuant to E.O. 14038 for having materially assisted,
sponsored, or provided financial, material, or technological support for, or goods or services
to or in support of, Peleng, a person whose property and interests are blocked pursuant to
E.O. 14038.
Oleg Yurchik (Yurchik) is a Belarusian national and the General Director of Shenzhen 5G.
OFAC is designating Yurchik pursuant to E.O. 14038 for being or having been a leader, o icial,
senior executive o icer, or member of the board of directors of Shenzhen 5G, an entity whose
property and interests are blocked pursuant to E.O. 14038.
Aliaksandra Aksianchuk (Aksianchuk) is a Belarusian national and the Production Director
of Shenzhen 5G. OFAC is designating Aksianchuk pursuant to E.O. 14038 for being or having
been a leader, o icial, senior executive o icer, or member of the board of directors of
Shenzhen 5G, an entity whose property and interests are blocked pursuant to E.O. 14038.
Dmitry Braim (Braim) is a Belarusian national and the Deputy Director General for Production
of Peleng. OFAC is designating Braim pursuant to E.O. 14038 for being or having been a leader,
o icial, senior executive o icer, or member of the board of directors of Peleng, an entity
whose property and interests are blocked pursuant to E.O. 14038.
Siarhai Charheika (Charheika) is a Belarusian national and the Head of the Planning and
Dispatch Department of Peleng. OFAC is designating Charheika pursuant to E.O. 14038 for
having acted or purported to act for or on behalf of, directly or indirectly, Peleng, a person
whose property and interests are blocked pursuant to E.O. 14038.
Dzmitry Mikhaltsou (Mikhaltsou) is a Belarusian national and the Technical Director of U.S.designated JSC Minsk Mechanical Plant Named A er S.I. Vavilov Management Company of
BelOMO Holding (BelOMO). Mikhaltsou signed an agreement with Yurchik of Shenzhen 5G for
casting molds and press molds. On December 5, 2023, OFAC designated BelOMO pursuant to
E.O. 14038 for being owned or controlled by, or having acted or purported to act for or on
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behalf of, directly or indirectly, the GoB, and for operating in the defense and related materiel
sector of the Belarus economy. OFAC is designating Mikhaltsou pursuant to E.O. 14038 for
being or having been a leader, o icial, senior executive o icer, or member of the board of
directors of BelOMO, an entity whose property and interests are blocked pursuant to E.O.
14038.

B ELARUS-SUPPLIED GRAY ARMS NET W ORK
Since at least 2015, Black Shield Company for General Trading LLC (Black Shield), an
ostensibly Iraq-based arms company led by Lebanon-based Samer Rayya (Rayya) and Syrian
Mohamad Majd Deiry (Deiry), has acquired and sold arms used in conflicts around the world,
including from key Belarusian defense company Kidma Tech OJSC, an entity designated by
OFAC on December 2, 2021. Rayya and Black Shield have a long history with Kidma Tech OJSC,
from procuring vehicles to be shipped to the Middle East, to discussions on setting up
companies in third countries to facilitate arms deals. In addition, Rayya and Deiry, through
Black Shield, have brokered weapons deals and o ered air transport services in the Middle
East and Africa for individuals, nonstate actors, and government customers, including from
Russian arms companies. Black Shield and Deiry maintained relationships with individuals
allegedly linked to the Syrian government and engaged in business activity on behalf of the
Iranian regime.
The Black Shield network specializes in buying and selling weapons and materiel, ranging from
ammunition, small arms, specialized sniper equipment and silencers, to armored vehicles,
tanks, military helicopters, artillery, surface to air missiles and anti-tank missiles. This also
includes specialized military technology like night vision equipment. The network uses
intermediary and front companies such as Centuronic Ltd (Centuronic) and S. Group
Airlines Ltd, both located in Cyprus, and Rayya Danişmanlik Hizmetleri Limited
Şirketi (Rayya Danismanlik), located in Turkiye, to conduct their business. Tatyana
Protopovich (Protopovich) is a director of Centuronic Ltd, and as CEO of Rayya Danismanlik,
Nora Yagmur (Yagmur) has participated in attempts to procure arms. Additionally,
Alhaitham Al Ali (Alhaitham) is a Slovak citizen and arms dealer who has acted as a
middleman for Black Shield in its arms deals with a European armaments firm. Alhaitham
specifically worked to assist Black Shield broker an arms deal between the European firm and
an African country, coordinating a contract for millions of rounds of ammunition, tens of
thousands of rifles and pistols, rocket propelled grenades, and indirect fire systems. Phoenix
Lines S.R.O. is a Slovakia-based company fully owned by Alhaitham.
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OFAC is designating Black Shield pursuant to E.O. 14038 for having materially assisted,
sponsored, or provided financial, material, or technological support for, or goods or services
to or in support of, Kidma Tech OJSC, a person whose property and interests are blocked
pursuant to E.O. 14038.
OFAC is designating Rayya and Deiry pursuant to E.O. 14038 for being or having been leaders,
o icials, senior executive o icers, or members of the board of directors of Black Shield, an
entity whose property and interests are blocked pursuant to E.O. 14038.
OFAC is designating Alhaitham pursuant to E.O. 14038 for having materially assisted,
sponsored, or provided financial, material, or technological support for, or goods or services
to or in support of, Black Shield, a person whose property and interests are blocked pursuant
to E.O. 14038.
OFAC is designating Phoenix Lines S.R.O. pursuant to E.O. 14038 for being owned or
controlled by, or having acted or purported to act for or on behalf of, directly or indirectly,
Alhaitham, a person whose property and interests are blocked pursuant to E.O. 14038.
OFAC is designating Centuronic, S. Group Airlines Ltd, and Rayya Danismanlik pursuant to E.O.
14038 for being owned or controlled by, or having acted or purported to act for or on behalf
of, directly or indirectly, Rayya, a person whose property and interests are blocked pursuant to
E.O. 14038.
OFAC is designating Protopovich pursuant to E.O. 14038 for being or having been a leader,
o icial, senior executive o icer, or member of the board of directors of Centuronic, an entity
whose property and interests are blocked pursuant to E.O. 14038.
OFAC is designating Yagmur pursuant to E.O. 14038 for being or having been a leader, o icial,
senior executive o icer, or member of the board of directors of Rayya Danismanlik, an entity
whose property and interests are blocked pursuant to E.O. 14038.

SANCT IONS IMPLICAT IONS
As a result of todayʼs action, all property and interests in property of the designated persons
described above that are in the United States or in the possession or control of U.S. persons
are blocked and must be reported to OFAC. In addition, any entities that are owned, directly
or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked
persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or
exempt, OFACʼs regulations generally prohibit all transactions by U.S. persons or within (or
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transiting) the United States that involve any property or interests in property of designated
or otherwise blocked persons.
In addition, financial institutions and other persons that engage in certain transactions or
activities with the sanctioned entities and individuals may expose themselves to sanctions or
be subject to an enforcement action. The prohibitions include the making of any contribution
or provision of funds, goods, or services by, to, or for the benefit of any designated person, or
the receipt of any contribution or provision of funds, goods, or services from any such person.
The power and integrity of OFAC sanctions derive not only from OFACʼs ability to designate
and add persons to the Specially Designated and Blocked Persons List (SDN List) but also
from its willingness to remove persons from the SDN List consistent with the law. The
ultimate goal of sanctions is not to punish but to bring about a positive change in behavior.
For information concerning the process for seeking removal from an OFAC list, including the
SDN List, please refer to OFACʼs FAQ 897.
Click here for more information on the individuals and entities sanctioned today.
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