• April 29, 2024

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OFAC Gives us Socks for Kingpin-ukkah

 OFAC Gives us Socks for Kingpin-ukkah
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For those of you who aren’t aware, June 1st is a major holiday in the sanctions world. Pursuant to §804(b) of the Foreign Narcotics Kingpin Designation Act,

“Not later than June 1, 2000, and not later than June 1 of each year thereafter, the President shall submit a report… (1) identifying publicly the foreign persons that the President determines are appropriate for sanctions pursuant to this Act; and (2) detailing publicly the President’s intent to impose sanctions upon these significant foreign narcotics traffickers pursuant to this Act.”

So every year on June 1st (or a few days before), sanctions-watchers everywhere rush down to their email inboxes to see what the Director of the Office of Foreign Assets Control has brought us this year for Kingpin-ukkah (or Kingpin-mas if you prefer). Sometimes, like last year, you get nothing. Other times you get a fun and interesting new toy, like 2013’s Mihael Karner steroids-related designation.

This year, we got… socks. Be still my heart.

Technically OFAC identified the Peruvian Moaist rebel group Shinging Path as a Significant Foreign Narcotics Trafficker. But for intents and purposes, designating Senderoso Luminoso is like getting socks for Hannukah.

The Shining Path is already designated as a Foreign Terrorist Organization (“FTO”) and a Specially Designated Global Terrorist (“SDGT”). Adding an [SDNTK] to Shining Path’s resume doesn’t add any additional compliance responsibilities given its other designations. It also doesn’t tell us anything that wasn’t already fairly well known.

Socks.

Now if the U.S. government really wanted to give us the Nintendo 64 of Kingpin designations, Congress has already suggested a good fit. At times, the international response to Hezbollah as been hampered by a mistaken tendency to view its military and political wings as separate. Hezbollah has long been involved in international narcotics trafficking, from South America to Europe to West Africa to Lebanon. A narcotics designation could potentially prod greater action to counter Hezbollah’s international networks, regardless of views on political/military “split,” as involvement in narcotics trafficking is universally viewed as a threat.

Samuel Cutler

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