FR 2021-01521

The Office of Foreign Assets Control (OFAC), a part of the U.S. Department of the Treasury, has recently made an update to its Specially Designated Nationals and Blocked Persons List. This list includes individuals and entities whose actions have met specific legal criteria under Executive Order 13818, which is aimed at addressing serious human rights abuses or corruption. The update results in the freezing of any properties or interests in property these individuals or entities may have under U.S. jurisdiction, and it generally prohibits U.S. persons from engaging in financial transactions with them.

One of the key elements of this document is its mention of the individuals and entities that have been designated as a result of these sanctions. However, it lacks detailed explanations for the specific actions or behaviors that led to the listing of Lazaro Alberto Alvarez Casas and the Ministry of Interior. The document only references these actors' involvement in human rights abuses and corruption under Executive Order 13818, leaving readers with minimal context.

The complexity of the legal references, particularly regarding Executive Order 13818, may pose challenges for a general audience. These references are not thoroughly explained, which could lead to misunderstandings for individuals not familiar with legal terminology or organizational specifics. Moreover, the document uses abbreviations such as "DOB" and "GLOMAG" without providing definitions or explanations, which may add to the confusion.

The lack of clarity extends to practical guidelines. For U.S. individuals and organizations potentially impacted by these sanctions, the document does not specify how they should comply or what steps they might need to take if they are currently engaged with the sanctioned entities or individuals. This could lead to uncertainty and inadvertent non-compliance, posing legal risks.

Broadly, this document may raise awareness of the U.S. government's enforcement actions against foreign individuals and entities involved in human rights abuses and corruption. This demonstrates a commitment to global human rights and the fight against corruption, principles likely to resonate with the public.

Specific stakeholders, such as businesses and financial institutions, might find this update troubling if they have existing transactions with the newly designated individuals or entities. They will need to conduct due diligence and potentially adjust their operations to remain compliant with the sanctions. On a positive note, these actions could benefit stakeholders and entities advocating for human rights and ethical governance, as they underscore a broader effort to sanction and curtail corrupt and abusive practices globally.

In conclusion, while the document is a critical update on OFAC's enforcement actions, the complexities and lack of detailed practical guidance may pose challenges to the public and specific stakeholders. Clearer communication and more comprehensive instructions could enhance understanding and ensure better compliance with these important legal measures.