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State Department formalizes PAIPA sanctions on Zelenyuk, Matrix LLC and Special Technology Services LLC FZ

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📅 02 November 2026 • Federal Register

Federal Register notice 2026-22248 formalizes PAIPA determinations
On 02 November 2026 the Federal Register published Doc 2026-22248, «Notice of Department of State Sanctions Actions» (Vol 91 No 210, public notice 13133). Per the Federal Register notice, it formalizes determinations signed February 24, 2026 by the US Secretary of State that the three named parties met the criteria of PAIPA section 2(a)(1)(A). The channel quotes this per the determination, not as its own claim.

The three parties, as printed in the notice
Per the notice, Zelenyuk and Matrix LLC are identified under section 2(a)(1)(A)(i) for knowingly engaging in, or benefitting from, significant theft of US trade secrets occurring on or after January 5, 2023, and Special Technology Services LLC FZ under 2(a)(1)(A)(iii) as owned or controlled by, or acting for, Zelenyuk. For the individual the notice prints screening identifiers: Sergey Sergeyevich Zelenyuk, listed location Saint Petersburg, alias MORTENOIR, date of birth March 17, 1994, taxpayer ID 780223642330.

Sanctions selected and already effective
Per the Federal Register notice, sanctions under PAIPA section 2(b)(1)(A), (D), (H), (I), (J) were selected for the entities, while the individual entry lists blocking of property printed as Sec.2(b)(2)(a). The determinations are effective February 24, 2026, so the property blocking described in the notice is already in force. The notice lists the contact as Andrew J. Weinschenk, Director, Office of Global Sanctions and Threat Finance (EBB). The notice expands PAIPA as the Protecting American Intellectual Property Act of 2022 (Pub. L. 117-336).

OFAC records for these parties
The notice itself does not mention OFAC. Per OFAC's recent actions page, its October 19, 2026 action «PAIPA Designations, Issuance of Associated General Licenses» added other parties to the Non-SDN Menu-Based Sanctions List and issued PAIPA General Licenses 1 and 2 — it does not concern this notice's parties. Per the State Department, OFAC designated all three named parties to the SDN list on February 24, 2026 under E.O. 13694, as amended by E.O. 14306.

Key figures

IMPACT
Who must act: banks, VASPs and compliance teams. Screen counterparties against the three named parties. Add the printed identifiers to screening tools. Reconcile with OFAC's February 24, 2026 SDN records for these parties before list updates. Blocking of property for the individual is already in force since February 24, 2026, per the determinations.

⚠️ Not fully verified — RF-adjacent item under the channel rule of strict neutral factology. Based on the official Federal Register notice, cross-checked with the State Department and Treasury releases.

Sources: federalregister.gov — home.treasury.gov — state.gov — ofac.treasury.gov

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