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Immigration & Visas

State Dept sanctions Russian trade-secret thief and firms

Sanctions under the Protecting American Intellectual Property Act now bind one Russian national and two companies, one in Russia and one in Dubai.

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Primary document: Notice of Department of State Sanctions Actions · Federal Register document number: 2026-22248

The State Department has put sanctions on a Russian national and two companies over the theft of trade secrets from United States persons. The notice, published in the Federal Register on November 2, 2026, says the determinations took effect on February 24, 2026. The document is at https://www.federalregister.gov/documents/2026/11/02/2026-22248/notice-of-department-of-state-sanctions-actions, and it is signed by Hugo Y. Yon, Principal Deputy Assistant Secretary in the Bureau of Economic, Energy, and Business Affairs.

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Sergey Sergeyevich Zelenyuk, Matrix LLC, and Special Technology Services LLC FZ are subject to the sanctions indicated, effective February 24, 2026.

This is a sanctions action, not a visa rule. Nothing in the notice changes how anyone applies for a visa, a residence permit or citizenship. If you are an expat, you are not the target here. But if you run a business, hold a stake in a Russian or Gulf firm, or do contract work on technology, the list matters to you.

Who is named

The notice names three targets under the Protecting American Intellectual Property Act of 2022 (PAIPA), Public Law 117-336.

The individual is Sergey Sergeyevich Zelenyuk, born 17 March 1994 in Saint Petersburg. The notice lists aliases, including "MORTENOIR" and "SRGSRGSRG111," and a Saint Petersburg address on Rimsky-Korsakov Prospect. It also gives a Russian tax ID number. Those details help banks and exporters screen names, so the notice gives them in full.

The first entity is Matrix LLC, a Saint Petersburg company established 27 September 2021. The notice also lists the names LLC MATRITSA, MATRIX LIMITED, MATRIX LTD, OPERATION ZERO and OPZERO, with the website opzero.ru.

The second entity is Special Technology Services LLC FZ, based at Meydan Grandstand in Dubai, United Arab Emirates. Its established date is 07 December 2024. The notice ties it to Zelenyuk. It was listed because it is owned or controlled by him, or acts for him, directly or indirectly, under PAIPA section 2(a)(1)(A)(iii).

The legal basis

The Secretary found that Zelenyuk and Matrix LLC met the test in PAIPA section 2(a)(1)(A)(i). That section covers a foreign person who has knowingly engaged in, or benefitted from, significant theft of trade secrets of United States persons. The theft must have occurred on or after January 5, 2023. It must also be reasonably likely to result in, or have materially contributed to, a significant threat to national security, foreign policy, or economic health or financial stability.

The notice does not say what the trade secrets were, who owned them, or how the theft happened. It gives no case facts at all. Readers who want that will have to look elsewhere, because this notice only records the designations and the sanctions chosen.

What the sanctions do

For the individual, the notice lists one measure: blocking of property under section 2(b)(2)(a).

For Matrix LLC, the Secretary chose five measures from PAIPA section 2(b)(1): subsections (A), (D), (H), (I) and (J). The notice shows these as the main list, with alternates for some of them. In plain terms, the list covers blocking of property, a bar on loans from United States financial institutions, limits on foreign exchange, limits on banking transactions, and a ban on investing in the equity or debt of a sanctioned person.

Special Technology Services LLC FZ received the same five measures from subsection (b)(1), and the notice lists them the same way. So the two companies are treated the same under the sanctions.

The notice does not spell out what each of these measures means in practice for a given transaction. A Dubai bank or a US lender would need to read PAIPA and their own compliance guidance for that. This notice is not a how-to.

Who is affected

Anyone who deals with these three names is the core audience. That means US persons who might do business with them, banks that process payments for them, and companies that share a supply chain with them. The Dubai address matters, because a company in the United Arab Emirates can be caught by a designation that started with a Russian individual.

If you are an expat with no ties to these firms, the notice does not reach you. Most readers of this site will not need to act on it at all.

What to do

The notice itself gives a contact for questions. It is Andrew J. Weinschenk, Director of the Office of Global Sanctions & Threat Finance, at (202) 647-5763. The notice also gives a Department of State email address, which is hidden behind protected email text in the published version, so use the phone number if you cannot read it.

If you are screening a counterparty, check the full names, aliases, addresses and tax IDs in the notice against your records. Those details are the only identifiers the notice gives.

What the notice leaves open

The notice does not say when the sanctions end, or whether they can be lifted. It does not give a route for a listed person or firm to ask for removal. It does not name the victims of the trade-secret theft, and it does not give the value of the stolen material. It also does not say whether any other person or company was considered and cleared.

The effective date is February 24, 2026, but the notice was published on November 2, 2026, more than eight months later. The notice does not explain the gap. Anyone relying on the date for a past transaction should check with counsel, since the document alone does not settle that question.

General information, not legal, immigration or tax advice. Confirm the details with State Department before you act.

Source: original report ↗

General information, not legal, immigration or tax advice. Confirm with the relevant government agency.

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