On December 9, 2021, International Anti-Corruption Day, the US Department of the Treasury’s Office of Foreign Assets Control designated 15 individuals and entities pursuant to Executive Order 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act and targets those who engage in corruption and serious human rights abuse. The designations were imposed upon 7 individuals from several countries in Central America, Africa, and Europe and 8 entities that they own or control, in an effort to expose systemic corruption and hold corrupt leaders accountable who, in the midst of a global pandemic, sought personal enrichment at the expense of the people that they were supposed to serve.
These actions by OFAC were complemented by the State Department’s visa restrictions imposed upon nine individuals involved in significant corruption pursuant to Section 7031 (c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2021. The actions are also in line with the new US Strategy on Countering Corruption released earlier this week by President Biden on December 6, 2021.
As a result of these designations, all property and interests in property of today’s designees within the United States or within the possession or control of a U.S. person are blocked, and U.S. persons are generally prohibited from engaging in transactions involving the designated persons. In addition, entities owned 50 percent or more by one or more blocked persons are also blocked.