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Financial Services Law Insights and Observations

OFAC sanctions Guatemalan officials

Financial Crimes Department of Treasury Of Interest to Non-US Persons OFAC SDN List Sanctions Guatemala OFAC Designations

Financial Crimes

On April 26, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13818 against one current and one former Guatemalan government official under the Global Magnitsky Human Rights Accountability Act. According to OFAC, the sanctioned persons “have directly or indirectly engaged in, corruption, including the misappropriation of state assets, the expropriation of private assets for personal gain, corruption related to government contracts or the extraction of natural resources, or bribery.” As a result of the sanctions, all property and interests in property belonging to the sanctioned persons, and “any entities that are owned, directly or indirectly, 50 percent or more” by them that are subject to U.S. jurisdiction are blocked and must be reported to OFAC. OFAC notes that its regulations generally prohibit U.S. persons from participating in transactions with these persons, which include “the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person or the receipt of any contribution or provision of funds, goods or services from any such person.”

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