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Financial Services Law Insights and Observations

OFAC and State Dept. announce additional corruption, human rights abuse sanctions

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

Financial Crimes

On December 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13818 targeting 15 individuals and entities connected to corruption and serious human rights abuse in several countries across Central America, Africa, and Europe under the Global Magnitsky Human Rights Accountability Act. OFAC noted that the designations were announced on International Anti-Corruption Day to “reinforce the priority placed upon curbing corruption through strategic and regulatory action at the Summit for Democracy.” As a result of the sanctions, all property and interests in property belonging to the sanctioned entities subject to U.S. jurisdiction are blocked and must be reported to OFAC. Additionally, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” OFAC noted 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.” In a complementary action, the U.S. Department of State also announced visa restrictions under Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, which targeted several corrupt officials and their immediate family members, making them ineligible to enter the U.S.