Villa S6/35, New Azadi Atconz, Ainkawa, Erbil, Iraq
Reg. ID
21756, Business Registration Number
Official reason
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. 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.
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, officials, senior executive officers, 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.
E.O. 14038. On August 9, 2021, the President, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), issued E.O. 14038. In E.O. 14038, the President expanded the scope of the national emergency declared in E.O. 13405, finding that the Belarusian regime's harmful activities and long-standing abuses aimed at suppressing democracy and the exercise of human rights and fundamental freedoms in Belarus including illicit and oppressive activities stemming from the August 9, 2020, fraudulent Belarusian presidential election and its aftermath, such as the elimination of political opposition and civil society organizations and the regime's disruption and endangering of international civil air travel—constituted an unusual and extraordinary threat to the national security and foreign policy of the United States.
