On September 15, 2020, the US Department of the Treasury’s Office of Foreign Assets Control designated the Union Development Group Co., Ltd. (UDG), a Chinese state-owned entity, for the seizure and demolition of land belonging to local Cambodians, for the construction of the Dara Sakor development project, a tourist destination. According to Secretary of Treasury Steven Mnuchin, UDG deceived officials by falsely registering as a Cambodian-owned entity in order to obtain land for the Dara Sakor project, then reverted to its true Chinese ownership in order to operate in Cambodia without repercussions. Since then, UDG has used the Cambodian military to intimidate local villagers into leaving the land, devastating the livelihoods of local communities and the environment, in order to benefit the People’s Republic of China at the expense of the Cambodian people.
The UDG was designated pursuant to Executive Order 13818, which implements the Global Magnitsky Human Rights Accountability Act, that targets individuals and entities responsible for human rights abuses and corruption. Some of UDG’s activities were ordered by Kun Kim, a senior Cambodian general who was designated by OFAC in 2019, pursuant to E.O. 13818, for his involvement in corruption. As a result, the UDG was designated for acting on behalf of a government official to engage in corruption, including the misappropriation of state assets, expropriation of private assets for personal gain, and corruption related to government contracts or the extraction of natural resources, or bribery.
As a result of this designation, all US property belonging to this entity is blocked, and transactions and dealings with this entity are generally prohibited. In addition, any entity in the US that is owned fifty percent or more by the sanctioned entity is also blocked.