The United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) has designated seven individuals and 2 entities as Specially Designated Nationals (“SDNs”) under the Anti Terrorism Sanctions Regulations, the Democratic Republic of Congo Sanctions Regulations, Non-proliferation Sanctions Regulations, and the Iranian Financial Sanctions Regulations, respectively.

Of these designated parties Treasury only released a press release on the four individuals designated under the Democratic Republic of Congo Sanctions Regulations. Those individuals are Gaston Iyamuremye, Leodomir Mugaragu and Felicien Nsanzubukire who are believed to serve as the leadership of the Democratic Forces for the Liberation of Rwanda (FDLR) and Innocent Zimurinda, an officer in the Congolese Armed Forces (FARDC). Zimurinda is alleged to have targeted children in connection with the conflict raging in the eastern part of the Democratic Republic of Congo.

The Democratic Republic of Congo sanctions were promulgated pursuant to Executive Order 13413 and targets those parties contributing to the conflict in the DRC. In accordance with their designations as SDNs, U.S. persons are prohibited from engaging in any transactions with these individuals, and any assets the designees have under U.S. jurisdiction are frozen. It should be noted that these individuals were previously sanctioned by the United Nations Security Council’s Committee established pursuant to Resolution 1533.

Gaston Iyamuremye, the FDLR’s president, Leodomir Mugaragu, the chief of staff of the FDLR’s military, and Felicien Nsanzubukire, an FDLR Lieutenant Colonel, are also accused of perpetuating instability in the Democratic Republic of Congo. In addition, Nsanzubukire is believed to be involved in the procurement and oversight of the FDLR’s ammunition and weapons supplies.

OFAC SDN designations can be challenged but is a long process and OFAC often takes months and sometimes years to reply to a request for reconsideration. If a party has been designated it behooves them to address the designation immediately, lest they face the consequences of the designation for a long time to come.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC litigation. If you have any questions please contact him at 202-280-6370 at 202-351-6161 or ferrari@ferrari-legal.com.