OFAC Designates Three Individuals and One Entity to Its Zimbabwe List (with Turza Comment)

On April 17, 2014, OFAC designated three individuals and one entity to its Zimbabwe list under Executive Order 13469 (signed July 25, 2008) for their role in "undermining democratic processes and institutions in Zimbabwe." According to the Department of Treasury press release, Tobaiwa Mudede, one of the designated individuals, oversaw "critical elements of Zimbabwe's flawed July 2013 presidential and parliamentary elections" in his role as Zimbabwe's Registrar General. The new designations also target Sam Pa, an Angolan businessman of Chinese descent who allegedly concluded illicit diamond deals in Zimbabwe and provided financial and logistical support to the country's intelligence service. The third individual designated was Jimmy Zerenie, a Zimbabwe-based Singaporean attorney who allegedly acted on Sim Pa's behalf by facilitating his illicit diamond dealings. Lastly, Sino Zim Development (Pvt) Ltd, a Zimbabwe-based company, was designated because, according to OFAC, it is owned or controlled by Zerenie and an unnamed senior Zimbabwean official. The sanctions subject each of the named individuals and Sino Zim to asset freezes.

Also in connection with the Zimbabwe sanctions program, OFAC announced the removal of a number of individuals and one entity from the Specially Designated Nationals list. While a number of the individuals who were delisted are now deceased, the Treasury has declined to comment on the reasons behind any of the removals.

Turza Comment: While diplomatic developments in Geneva appear to have reduced the likelihood of new Ukraine-related sanctions in the immediate future, OFAC's action today reminds us that the United States maintains an active portfolio of sanctions programs, which U.S. companies must monitor vigilantly for any potential impact on their business activities.

See: Executive Order 13469; Specially Designated Nationals List Amendments; Treasury Press Release.