Treasury Targets Support to Designated Corrupt Actors

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