December 11, 2024

United States imposes new designations to mark International Anti-Corruption Day and International Human Rights Day

On December 9, 2024, on International Anti-Corruption Day, the U.S. Department of the Treasury’s Office of Foreign Assets Control designated 28 individuals and entities for enabling a Zimbabwe-based global gold smuggling and money laundering network led by Kamlesh Pattni.  According to OFAC, Pattni is a UK citizen who uses his global network to facilitate illicit bribery and money laundering schemes that generate cash by selling Zimbabwean natural resources, including gold and diamonds, in foreign jurisdictions.  OFAC reported that, when Pattni returns to Zimbabwe, he overreports the amount of cash he obtains in the scheme and receives compensation for the overreported cash.  To conceal this scheme, Pattni bribes Zimbabwean government officials and has his global network of companies launder the funds.  The new designees include Pattni and multiple members of his corrupt network, including Sanjay Keshavji Vaya who is considered to be Pattni’s “right hand man” for Zimbabwe-related activities.

According to OFAC, this action was the result of a collaborative effort with the Federal Bureau of Investigation and the United Kingdom, which resulted in the designation of Pattni and additional individuals in the UK.

These designations were imposed pursuant to Executive Order 13818, which builds upon and implements the Global Magnitsky Human Right Accountability Act that targets those who engage in serious human rights abuse and corruption around the world.  As a result of these designations, all property and interests in property of the 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 designated persons are also blocked, unless they are exempt or authorized by a general or specific license issued by OFAC.

On December 9, 2024, OFAC also announced new designations in recognition of International Human Rights Day, which is observed every year on December 10.  OFAC marked the day by designating the Houthi National Committee for Prisoners’ Affairs and its leader Abdulqader Al-Murtadha for engaging in serious human rights abuse in connection with the systematic torture and inhumane treatment of prisoners in Houthi-run prisons in Yemen.  These designations were imposed pursuant to EO 13818.  OFAC also designated Fawaz al-Akhras, a supporter of Syria’s al-Assad regime who allegedly helped Bashar-al-Assad (who has been designated for perpetrating serious human rights abuses in Syria) with financial matters, sanctions evasion efforts, and attempted international political engagements.  This designation was imposed pursuant to EO 13894 for engaging in actions or policies that threaten the peace, security, stability, or territorial integrity of Syria.

In honor of International Anti-Corruption Day and International Human Rights Day, the U.S. State Department also took steps to impose visa restrictions on more than a dozen individuals pursuant to 212(a)(3)(C) of the Immigration and Nationality Act.  The Department also designated one official for engaging in a gross violation of human rights pursuant to 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act.  The Department also announced that it issued its first visa restriction under a new authority that denies safe haven to actors who enable corruption.

U.S. Department of Treasury Press Release I | U.S Department of Treasury Press Release II | U.S. Department of State Press Statement