On March 17, 2022, the US Department of the Treasury’s Office of Foreign Assets Control designated Alain Goetz, a businessman in Belgium who controls a network of companies allegedly involved in the illicit export of hundreds of millions of dollars of gold per year from the Democratic Republic of the Congo (DRC). OFAC also designated nine of Goetz’s companies, including the African Gold Refinery (AGR) in Uganda, in an effort to disrupt the illicit mineral trade in the DRC and encourage transparency in its mining sector. OFAC reports that the DRC’s gold trade is a major driver of conflict in the region, comprised of a network of armed groups, smugglers and companies that generate revenues through the use of forced labor and the extortion of payments from miners. According to OFAC, network participants use the revenues to enrich themselves and finance armed conflicts while disregarding the environment and local communities and depriving the DRC of tax revenue.
OFAC reports that the AGR was designated pursuant to EO 13413 for being responsible for or complicit in the support of persons involved in activities that threaten the peace or stability of the DRC or undermine its democratic processes or institutions. Goetz and the other entities were also designated pursuant to EO 13413 – Goetz for being the leader of AGR and the other eight entities for being owned or controlled by Goetz.
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 US person are blocked, and US persons are generally prohibited from engaging in transactions involving the designated persons unless authorized by OFAC. In addition, entities owned fifty percent or more by one or more designated persons are also blocked.