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Financial Services Law Insights and Observations

OFAC Announces Honduras-Based Bank as Specially Designated Narcotics Trafficker

Anti-Money Laundering OFAC

Federal Issues

On October 7, OFAC announced the designation of a Honduras-Based bank (the Bank) as a Specially Designated Narcotics Trafficker. According to the Department of the Treasury, this announcement “marks the first time that OFAC has designated a bank pursuant to the [Foreign Narcotics Kingpin Designation Act].” OFAC alleged that the Bank was an integral part of a money laundering operation that “facilitated the laundering of narcotics proceeds for multiple Central American drug trafficking organizations.” In addition to the Bank’s designation, OFAC announced the designation of three Honduran businessmen for supporting, via money laundering and other services, the international trafficking of narcotics for the same Central American criminal organizations. The Government of Honduras informed OFAC on October 10 that the liquidation process for the Bank was in effect. Non-U.S. persons involved in the Bank’s liquidation process will not be subject to OFAC designations or enforcement actions, with the understanding that “they do not undertake such transactions with knowledge that such transactions involve or benefit, directly or indirectly, any individual or entity other than [the Bank] that is listed on OFAC’s List of Specially Designated Nationals or Blocked Persons or that otherwise constitutes a person whose property and interests in property are blocked.” Liquidation transactions involving U.S. persons or financial institutions are prohibited, unless the individual or entity applied for and received OFAC authorization.