ANTI CORRUPTION ASSET RECOVERY

Treasury Targets Support to Designated Corrupt Actors

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Washington – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) des­ig­nat­ed Zineb Souma Yahya Jammeh (Zineb) and Nabah LTD (Nabah) for their roles in pro­vid­ing sup­port to per­sons pre­vi­ous­ly des­ig­nat­ed for their own cor­rupt behav­ior. 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 for or on behalf of, direct­ly or indi­rect­ly, 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.

View iden­ti­fy­ing infor­ma­tion on the indi­vid­ual and enti­ty des­ig­nat­ed today.

U.S. DEPARTMENT OF THE TREASURY

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