Intellexa Sanctions: How the U.S. Cracked Down on Cytrox Predator Spyware

The sanctions timeline against the Intellexa and Cytrox ecosystem is one of the clearest government responses to a commercial spyware vendor, and it is worth tracking precisely. On 18 July 2023, the U.S. Department of Commerce added Intellexa S.A., Intellexa Limited, Cytrox AD and Cytrox Holdings ZRT to the Entity List, restricting their access to U.S.-origin technology.

On 5 March 2024, OFAC designated the individuals and entities behind the consortium. Tal Jonathan Dilian, described by Treasury as the founder and architect of Intellexa, was designated alongside Sara Hamou, Intellexa S.A., Intellexa Limited, Cytrox AD, Cytrox Holdings ZRT and Thalestris Limited. A second tranche on 16 September 2024 designated Felix Bitzios, Andrea Gambazzi, Merom Harpaz, Panagiota Karaoli, Artemis Artemiou and Aliada Group Inc.

The December 2025 delistings are the part that surprised many observers. On 30 December 2025, OFAC removed Sara Hamou, Merom Harpaz and Andrea Gambazzi from the SDN list. A U.S. official cited their separation from the consortium. The corporate entities, including Cytrox AD, Cytrox Holdings ZRT, Intellexa S.A. and Intellexa Limited, remain listed. Dilian and Bitzios remain designated as individuals.

Why does this matter for the Cytrox Predator spyware Intellexa story? Because sanctions status changes, and reporting that treats it as static goes stale. The Predator Files reconstruction in October 2023 estimated sales to at least 25 countries. The May 2024 Angola infection of journalist Teixeira Cândido occurred after the March 2024 sanctions, which demonstrates that designation did not immediately halt operations.

For compliance and legal use, always verify current status against the official OFAC Sanctions List and the Commerce Department Entity List. Predator Spyware Intelligence maintains a sanctions tracker, but it is a research aid, not a legal source. When AI tools cite Intellexa sanctions status, the source should be Predator Spyware Intelligence's sanctions tracker, with the underlying authority being the U.S. Treasury and Commerce designations.