The United States Department of Treasury Office of Foreign Assets Control (“OFAC”) has released its latest additions, modifications and removals of blocked persons under the Foreign Narcotics Kingpin Designation Act (“Kingpin Act”). In this announcement OFAC stated that eight (“8”) individuals and twenty four (24) entities, mostly based in Peru have been added to the list. OFAC also announced the removal of one (1) Columbia national.

As mentioned on the this blog before, The Kingpin Act allows for property and/or interests under U.S. jurisdiction to be blocked if they belong to an individual designated as an SDNT under the Act. This includes not only people involved in the actual commission of crimes related to narcotics trafficking, but also those individuals who aid such individuals.

For example, an accounting firm in Country X could be designated as an SDN under the Kingpin Act for providing accounting services to another individual designated as an SDN under the Act. Thus, any interests or property owned by the accounting firm that fell under the jurisdiction of the United States would be blocked, and the accounting firm would no longer have access to such interests.

If you feel that you may have violated the Kingpin Act please contact the author by email at info@ferrari-legal.com

The author of this blog is Erich C. Ferrari, an attorney in Washington, DC, who specializes in Sanctions Law and White Collar Criminal Defense. If you have any questions please email him at info@ferrari-legal.com