Belarus Sanctions Broadened

In an effort to further isolate the Russian and Belarus military-industrial complex,  the U.S. Treasury’s Office of Foreign Assets Control (OFAC) is designating 12 entities and 10 individuals pursuant to Executive Order (E.O.) 14038, 

The individuals and entities OFAC is targeting include six revenue-generating state-owned 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 Belarus’s extensive illicit facilitation networks and hold the regime accountable for its complicity in, and profiteering from, Russia’s unjust war in Ukraine.”

Included in this designations is a coordinated action with the Department of Justice and Federal Bureau of Investigation. Concurrent with these 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  in the Southern District of Florida. Deiry and Rayya remain at large and wanted by the Federal Bureau of Investigation.

Today’s designations also coincide with a separate sanctions action against Belarus by the Government of Canada.

REVENUE GENERATING STATE-OWNED ENTERPRISES

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. 

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 —and had an operating revenue of $40 million in 2022.

AGAT is the management company for four additional entities located in Belarus that OFAC is also designating:

• 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.
• 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. 
• LLC InnoTech Solutions is a software 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.  

PELENG FACILITATION NETWORK

U.S.-designated Belarusian SOE Peleng JSC (Peleng) is a leading design enterprise in the Belarusian optoelectronic industry and is one of Russia’s most important industrial suppliers in Belarus. OFAC designated Peleng on December 2, 2021, 

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. 

Shenzhen 5G High-Tech Innovation Co., Limited (Shenzhen 5G) is a People’s 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 Peleng’s 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.

BELARUS-SUPPLIED GRAY ARMS NETWORK 

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 offered 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.

[Full Treasury Press Release}

Click here for more information on the individuals and entities sanctioned today.