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OFAC Sanctions DRC Associates of Sanctioned Billionaire in Conjunction with New Strategy on Countering Corruption and Global Magnitsky Designations

By Nicholas Turner, Jack Hayes, Evan Abrams, Dave Stetson, Ed Krauland & Wendy Wysong on December 10, 2021
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On December 6, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) named one individual and 12 entities in the Democratic Republic of the Congo and Gibraltar as Specially Designated Nationals (SDNs) pursuant to the Global Magnitsky Sanctions program under Executive Order (EO) 13818.

The newly designated SDNs are part of a network of individuals and companies alleged to have provided material “support to sanctioned billionaire Dan Gertler,” who was designated under EO 13818, in December 2017, for allegedly engaging in significant corruption in the DRC mining and oil sectors. There are now 46 persons designated under EO 13813 in connection with Gertler.

EO 13818 authorizes OFAC to designate as SDNs foreign persons determined to be involved in serious human rights abuses or corruption globally. All property and interests in property of these SDNs (and any entity that is owned 50 percent or more by one or more SDNs) must be “blocked,” i.e., frozen if within the United States or in the possession or control of a US person. Additionally, there is a broad prohibition on dealing directly or indirectly with the SDNs or their “blocked” property to the extent US persons are involved.

Also, on December 6, 2021, the Biden administration announced a new US Strategy on Countering Corruption outlining steps that could strengthen the government’s “ability to prevent corruption, more effectively combat illicit finance, better hold corrupt actors accountable, and strengthen the capacity of activists, investigative journalists, and others on the front lines of exposing corrupt acts.”

Meanwhile, Deputy Treasury Secretary Wally Adeyemo gave a speech outlining a range of actions being taken by the Treasury Department to combat corruption worldwide and to limit the flow of illicit funds into the United States, including through the adoption of blocking sanctions and a proposed rulemaking aimed at increasing transparency in all-cash real estate transactions, among other actions.

According to Adeyemo, the brother of former DRC president Joseph Kabila, who facilitated Gertler’s allegedly corrupt deals, reportedly took advantage of lax US anti-money laundering rules to invest nearly $3.5 million of embezzled DRC government funds into US real estate.

The Treasury Department’s news release states that the DRC-related sanctions are part of a series of designations under the Global Magnitsky program planned to coincide with International Anti-Corruption Day and International Human Rights Day. On December 7, 8, and 9, OFAC announced the designations of individuals and entities in Angola, Bangladesh, China, El Salvador, Guatemala, Iran, Kosovo, Liberia, Myanmar, North Korea, South Sudan, Syria, Uganda, and Ukraine in connection with allegations of serious human rights abuses and corruption in those countries. The Treasury announcements regarding those designations are available here, here, here, and here.

See this blog post for details about the US Treasury Department’s proposed rulemaking for all-cash real estate transactions.

For more information on how these developments may apply to your organization, contact a member of Steptoe’s Economic Sanctions team.

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Photo of Jack Hayes Jack Hayes

Jack Hayes has extensive experience providing clients with advice and assistance under ITAR and EAR, as well as US economic sanctions and anti-boycott regulations. Jack frequently handles complex export control matters, including voluntary disclosures, internal investigations of apparent export control violations, pre-closing and…

Jack Hayes has extensive experience providing clients with advice and assistance under ITAR and EAR, as well as US economic sanctions and anti-boycott regulations. Jack frequently handles complex export control matters, including voluntary disclosures, internal investigations of apparent export control violations, pre-closing and post-closing acquisition export compliance due diligence, export control audits, and assessments of compliance obligations and risks in accordance with relevant international trade regulations. He also provides guidance on brokering requirements and reporting obligations for certain fees, commissions, and political contributions related to sales of defense articles and defense services, prepares export and reexport license and agreement applications for submission, undertakes commodity jurisdiction and export classification analyses of items and services under the ITAR and EAR, drafts registration material change notifications, and develops compliance policies, programs, and training materials.

Read Jack’s full bio.

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Photo of Evan Abrams Evan Abrams

Evan Abrams counsels multinational corporations, financial institutions, and individuals on various international regulatory and compliance matters. He assists foreign and domestic companies in navigating national security reviews by the Committee on Foreign Investment in the United States (CFIUS). He has represented companies in…

Evan Abrams counsels multinational corporations, financial institutions, and individuals on various international regulatory and compliance matters. He assists foreign and domestic companies in navigating national security reviews by the Committee on Foreign Investment in the United States (CFIUS). He has represented companies in industries including semiconductors, metals, and digital security. Evan’s anti-money laundering (AML) practice focuses on helping financial institutions comply with federal and state AML rules, particularly money transmitters and entities involved in creating, exchanging, or dealing in cryptocurrencies and tokens. Evan counsels clients in a variety of export controls and sanctions matters related to the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), and various sanctions programs under US and international law. In addition, Evan routinely assists clients on anti-corruption investigations and enforcement actions.

Read Evan’s full bio.

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Photo of Ed Krauland Ed Krauland

Edward J. Krauland focuses on export controls/economic sanctions. Ed’s extensive experience includes representing clients on matters involving US and multilateral economic sanctions, defense and nuclear export controls, dual-use export controls under the EAR, anti-boycott compliance, internal investigations and enforcement work, and review of…

Edward J. Krauland focuses on export controls/economic sanctions. Ed’s extensive experience includes representing clients on matters involving US and multilateral economic sanctions, defense and nuclear export controls, dual-use export controls under the EAR, anti-boycott compliance, internal investigations and enforcement work, and review of government procurement regulations in the cross-border context. His practice spans all aspects of these laws, including counseling, compliance work, transactional advice, licensing and opinion work, internal reviews, disclosures, and enforcement actions. He has served as co-chair of the International Trade Committee of the ABA Section of International Law and Practice. He is former Chairman of an ABA-wide Task Force on Gatekeeper Regulation (anti-money laundering compliance), and senior adviser to the ABA Section of International Law and Practice’s anti-money laundering committee.

Read Ed’s full bio.

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  • Posted in:
    Government and Public Policy
  • Blog:
    International Compliance Blog
  • Organization:
    Steptoe LLP

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