Nicaragua Sanctions

OFAC issues regulations for the implementation of sanctions in Nicaragua

Nicaragua Sanctions

On 5th September, OFAC issued a regulation to implement Executive Order (EO) 13851 related to the situation in Nicaragua, signed on 27th November 2018. The EO blocks the property of persons who served as officials to the Nicaraguan government at any time after January 10, 2007, as well as persons responsible for or complicit in serious human rights violations that undermine democracy, threaten peace and security.

In addition, the order blocks leaders or officials of entities that have participated in such practices, as well as entities owned by persons blocked by the Order.

It also authorizes the United States Government to block the property of any person, including non-U.S. persons, who assist or provide financial, material or technological support, or goods or services in support of persons and entities blocked by the Order, in addition to persons who support human rights abuses, threats to peace and security, corruption and other activities described in the Order. However, it does not restrict general exports or imports involving Nicaragua.

This year, the U.S. government has taken steps to put pressure on Nicaraguan President José Ortega. On December 20, 2018, President Trump enacted the Nicaraguan Human Rights and Anti-Corruption Law, which restricts international funding and imposes new sanctions on institutions and individuals responsible for the Nicaraguan government’s violence and violation of demonstrators’ civil rights. In April 2019, the United States sanctioned Ortega’s son, as well as Banco Corporativo SA (Bancorp). In June, the U.S. Government and Canada announced sanctions against four other Nicaraguan government officials.

These new regulations provide for a number of exempt transactions and authorizations, including:

  • Transactions related to personal communications.
  • Import or export of any information or informational material.
  • Transactions normally related to travel to or from any country, including the payment of living expenses and the acquisition of goods for personal use.
  • Payments related to the provision of certain legal services.
  • Provision of emergency medical services.

OFAC intends to supplement these standards in the future.