The United States Department of the Treasury Office of Foreign Assets Control (OFAC) has targeted Badruddin Haqqani for sanctions pursuant to the Global Terrorist Sanctions Regulations. As a result, Haqqani has been targeted as a Specially Designated Global Terrorist (SDGT) and has been placed on OFAC’s List of Specially Designated Nationals (SDNs). The consequences of this designation is that all of Haqqani’s assets in the U.S. have been blocked and all U.S. persons are prohibited from engaging in transactions with him.

According to OFAC, Haqqani, a Pakistani national, is alleged to be the Operational Commander of the Haqqani Network. It is believed that the Haqqani network is an independent insurgent group in Afghanistan and Pakistan that is closely allied with the Taliban. In addition, some sources believe that the network is one of the biggest threats to NATO and United States forces in Afghanistan. It is believed that the network maintains ties with the Pakistani Inter-Services Intelligence and the Pakistani Army has been reluctant to move against them.

The consequences of an OFAC SDN designation can be devastating. Having represented clients in removal proceedings related to these designations it is clear that OFAC’s determination that someone should be targeted for economic sanctions has a devastating, if not a life altering effect. What is most concerning about this process is the fact that both the designation and removal aspects of it are completely controlled by OFAC and within their discretion. As such, a designation can seemingly be made out of nowhere, while the removal of that designation can be a complicated matter lasting for a number of years.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com.

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