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Financial Services Law Insights and Observations

OFAC Issues Statement Regarding May Kingpin Act Designations

OFAC

Federal Issues

Last month, OFAC designated as Specially Designated Narcotics Traffickers (SDNTs) an alleged Panamanian money laundering organization and its leaders, as well as six associates who, according to OFAC, provided material support and/or acted on behalf of the organization. OFAC also designated 68 companies connected to the organization, including Felix B. Maduro, S.A., Importadora Maduro, S.A., and Maduro Internacional, S.A. (the “Felix Maduro Group”), for being owned or controlled by the designated individuals. According to a June 1 statement, the Government of Panama is working to sever the SDNTs’ ownership and control of the Felix Maduro Group so as “to protect the Panamanian and U.S. financial systems from abuse.” As such, OFAC advised that it would not impose sanctions on non-U.S. persons for engaging in transactions related to the removal of the SDNTs’ ownership, provided certain conditions are met. Additionally, OFAC advised that to the extent such transactions may involve U.S. persons or implicate U.S. jurisdiction, involved parties should apply for a specific license from OFAC.