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Financial Services Law Insights and Observations

OFAC sanctions Zimbabwean persons

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

Financial Crimes

On December 12, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13469 against four Zimbabwean individuals, including the son of the President of Zimbabwe, and two Zimbabwean entities connected to a previously designated individual and his company that were sanctioned for materially assisting, sponsoring, or providing financial, material, logistical, or technical support for the Government of Zimbabwe. As a result of the sanctions, all property and interests in property belonging to the sanctioned persons that are in the U.S. or in the possession or control of U.S. persons, and “any entities that are owned, directly or indirectly, 50 percent or more in the aggregate by one or more of such persons are also blocked.” Additionally, U.S. persons are prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons, unless exempt or authorized by a general or specific OFAC license.

OFAC also removed seventeen Zimbabweans from the Specially Designated Nationals and Blocked Persons List after determining that they “no longer undermine Zimbabwe’s democratic processes and institutions or meet any of the other criteria for designation under OFAC’s Zimbabwe sanctions program.”