Today The United States Department of the Treasury Office of Foreign Assets Control (OFAC) has removed sanctions on a large number of individuals and entities placed on OFAC’s Specially Designated Nationals List pursuant to Executive Order (E.O.) 12978. E.O. 12978 was issued on October 21, 1995 to target for sanctioning narcotics traffickers located in Columbia. These types of designations are identified on the Specially Designated Nationals list as SDNT.

The Narcotics Trafficking Sanctions Regulations are not utilized as often by OFAC as the Foreign Narcotics Kingpin Designations Sanctions Regulations (Kingpin), which is the other sanctions program at OFAC’s disposal to combat narcotics trafficking. In fact, this preference for the Kingpin designations is so pronounced that despite numerous Kingpin designations in the same time, there have not been any SDNT designations since July 15, 2010. However, since July 15, 2010 sixty-one (61) SDNT’s have been removed from the list, including the twenty-five (25) that were removed today.

On another note, the most recently designated SDNTs to be removed as part of today’s action are Diego Uriel Alzate Jimenez, Luis Holmes Alzate Jimenez, Tulio Hernando Alzate Jimenez. At the time of there designations these three men were thought to be key players in the North Calle Cartel Financial Network.

All three men were designated on October 10, 2007. Although we cannot be sure of the circumstances surrounding their removal from the list, it is certain that they were on the list for nearly four (4) years. Moreover, all of the other parties removed as part of today’s action were on the list for at least that amount of time and in most cases much longer. This once again shows that an OFAC designation can last a very long time, no matter how quickly the request for reconsideration is submitted. I have personally handled a number of designation removal cases and can attest to the fact the process if a slow one. The best advice I can provide to those finding themselves on the Specially Designated Nationals List is to submit their request for reconsideration and to respond to OFAC’s request for information as quickly as possible.

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.