Today, the Department of State announced the designations of one individual and two entities under the Protecting American Intellectual Property Act (PAIPA) in connection with theft of trade secrets from U.S. persons. Matrix LLC (AKA Operation Zero) is a Russian cyber-tools broker that publicly advertises itself as a reseller of cyber exploits to various customers, including the Russian government. From 2022 to 2025, Peter Williams, an Australian national, stole eight trade secret “zero-day exploits,” techniques that leverage software vulnerabilities for which there are no patches, from his employer, a U.S. defense contractor.
Background and Key Details
Those components were meant to be sold exclusively to the U.S. government and select allies. He sold these exploits to Operation Zero in exchange for $1.3 million in cryptocurrency payments. Sergey Sergeyevich Zelenyuk (Zelenyuk) is a Russian national and the director and sole owner of Operation Zero.
Moreover, zelenyuk established a UAE-based company under the name Special Technology Services LLC FZ (STS), anticipating that the new company would conduct business with various countries in Asia and the Middle East. Zelenyuk’s effort to establish this company was likely aimed in part at circumventing U.S. sanctions imposed on Russian bank accounts. Operation Zero and Zelenyuk are foreign persons that knowingly engaged in. Benefitted from, significant theft of trade secrets of United States persons, which occurred on or after January 5, 2023, and is reasonably likely to result in, or has materially contributed to, a significant threat to the national security, foreign policy, or economic health or financial stability of the United States.
STS is an entity that is owned or controlled by. That has acted or purported to act for or on behalf of, directly or indirectly, Zelenyuk. Concurrently, the Department of Treasury is designating Zelenyuk and his company, Matrix LLC (doing business as Operation Zero), STS, as well as four associated individuals and entities pursuant to Executive Order (E.O.) 13694, as further amended by E.O. 14306.
Enforcement Actions and Impact
As a result of today’s action under E.O. 13694, as amended, all property and interests in property of those designated that are in the United States or that are in possession or control of a U.S. person are blocked. U.S. persons are generally prohibited from conducting business with sanctioned persons. Persons that engage in certain transactions or activities with those designated may expose themselves to sanctions risk. For complete details, refer to the official OFAC press release.
As a result of the designations under PAIPA, the sanctions specified in Section 2(b)(1)(A), (D), (H), (I). (J) of the statute apply with respect to Operation Zero and STS. Individuals designated under PAIPA are subject to the sanctions for individuals outlined in Section 2(b)(2) of the statute. For related coverage, see F-35 Fighter Jet Becomes $2 Trillion Disaster as Allies Abandon Costly Jet Amid Broken Promises.
Consequently, today’s action is being taken pursuant to the authorities under the Protecting American Intellectual Property Act (50 U.S.C. 1709) and Executive Order (E.O.) 13694, as amended. For further information, please submit a media inquiry, or visit our Cyber Sanctions page. For related coverage, see Europe Jolted as Portugal’s President Declares Trump “Objectively a Soviet Agent” Helping Moscow.
What This Means Going Forward
This development underscores the ongoing regulatory enforcement priorities of OFAC. Market participants and compliance professionals should monitor this matter closely.
