OFAC designated these persons pursuant to Executive Order (E.O.) 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act and targets perpetrators of serious human rights abuse and corruption.
“Bad actors rely on their networks and front companies to evade sanctions and conceal their illicit activities,” said Deputy Secretary Justin G. Muzinich. “We will continue to use our authorities to prevent such illicit funds from moving freely through the international financial system.”
ZINEB SOUMA YAHYA JAMMEH
Zineb is the former First Lady of The Gambia and the current wife of Yahya Jammeh (Jammeh), who is a former President of The Gambia who came to power in 1994 and stepped down in 2017. Jammeh was previously included on the Annex to E.O. 13818 on December 21, 2017, for his long history of engaging in serious human rights abuse and corruption. During his tenure, Jammeh used a number of corrupt schemes to plunder The Gambia’s state coffers or otherwise siphon off state funds for his personal gain. At the time of his designation, ongoing investigations revealed Jammeh’s large-scale theft from state coffers prior to his departure. According to The Gambia’s Justice Ministry, Jammeh personally, or through others acting under his instructions, directed the unlawful withdrawal of at least $50 million of state funds. The Gambian Government had since taken action to freeze Jammeh’s assets within The Gambia.
Zineb has reportedly been instrumental in aiding and abetting Jammeh’s economic crimes against the country, and despite numerous calls for Zineb to intervene, has turned a blind eye to Jammeh’s human rights abuses. Zineb is also believed to be in charge of most of Jammeh’s assets around the world, and utilized a charitable foundation as cover to facilitate the illicit transfer of funds to her husband. The Department of Justice filed a civil forfeiture complaint on July 15, 2020, seeking the forfeiture of a Maryland property acquired with approximately $3,500,000 in corruption proceeds by Jammeh, through a trust set up by his wife, Zineb.
Zineb is designated for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of Jammeh.
NABAH LTD
Nabah is owned or controlled by Ashraf Seed Ahmed Al-Cardinal (Al-Cardinal) and is registered in the United Kingdom. Al-Cardinal was previously designated on October 11, 2019, for his involvement in bribery, kickbacks and procurement fraud with senior government officials. Al-Cardinal himself was part of a sanctions evasion scheme in which a senior South Sudanese official used a bank account in the name of one of Al-Cardinal’s companies to store his personal funds in an attempt to avoid the effects of U.S. sanctions. Al-Cardinal and his companies act as intermediaries to deposit and hold large amounts of funds for senior-level South Sudanese officials outside of South Sudan in an attempt to avoid sanctions.
Nabah is designated for being owned or controlled by, or for having acted or purported to act on behalf of, directly or indirectly, for Al-Cardinal.
ADDRESSING SANCTIONS EVASION
The Treasury Department continues to target enablers of corruption, money launderers, and terrorist financiers who use front companies, real estate, and other methods, often in the name of relatives or associates, to conceal beneficial ownership of ill-gotten proceeds and to establish businesses to evade sanctions. This practice is particularly detrimental when it involves foreign political officials who can leverage state institutions and the appearance of legitimacy to facilitate large-scale money movements, control of lucrative public resources, or trade in illicit goods.
The Department of the Treasury promotes international anti-money laundering and countering the financing of terrorism (AML/CFT) standards with partners around the world to reduce opportunities for abuse of the global financial system. Treasury works with foreign governments and multilateral partners as well as financial institutions, money transmitters, broker-dealers, the real estate sector, and other applicable sectors to inform them of illicit finance risks and ensure that AML/CFT and sanctions measures are properly designed and implemented. Treasury has also issued targeted advisories to assist in identifying potential sanctions evasion activity.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the individual and entity above, and of any entities that are owned, directly or indirectly, 50 percent or more by them, individually, or with other blocked persons, that are in the United States or in the possession or control of U.S. persons, are blocked and must be reported to OFAC. Unless authorized by a general or specific license issued by OFAC or otherwise exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person or the receipt of any contribution or provision of funds, goods or services from any such person.
GLOBAL MAGNITSKY
Building upon the Global Magnitsky Human Rights Accountability Act, the President signed E.O. 13818 on December 20, 2017, in which the President found that the prevalence of human rights abuse and corruption that have their source, in whole or in substantial part, outside the United States, had reached such scope and gravity that it threatens the stability of international political and economic systems. Human rights abuse and corruption undermine the values that form an essential foundation of stable, secure, and functioning societies; have devastating impacts on individuals; weaken democratic institutions; degrade the rule of law; perpetuate violent conflicts; facilitate the activities of dangerous persons; and undermine economic markets. The United States seeks to impose tangible and significant consequences on those who commit serious human rights abuse or engage in corruption, as well as to protect the financial system of the United States from abuse by these same persons.
