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Financial Services Law Insights and Observations

OFAC sanctions persons linked to Democratic Republic of Congo

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

Financial Crimes

On December 6, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13818 against an individual and 12 associated entities in the Democratic Republic of the Congo and Gibraltar under the Global Magnitsky Human Rights Accountability Act. All of the designated persons have allegedly provided support for a previously sanctioned billionaire, OFAC stated, adding that these measures build upon Treasury’s commitment to “supporting the Democratic Republic of the Congo’s anti-corruption efforts by going after those that abuse the political system for economic gain and unfairly profit from the Congolese state.” 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 noted that its regulations generally prohibit U.S. persons from participating in transactions with these individual and entities unless authorized by a general or specific license. This includes “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.”