About 3 PM on Tuesday, OFAC created a brand-new sanctions program – Nicaragua-related Sanctions. There were two persons designated:
MONCADA LAU, Nestor (a.k.a. “CHEMA”); DOB 02 Mar 1954; POB Managua, Nicaragua; nationality Nicaragua; Gender Male (individual) [NICARAGUA].
MURILLO DE ORTEGA, Rosario Maria, Managua, Nicaragua; DOB 22 Jun 1951; nationality Nicaragua; Gender Female; Passport A00000106 (Nicaragua) (individual) [NICARAGUA].
and an Executive Order from President Trump. Here are the conditions which Treasury and State can use to designate someone:
(i) to be responsible for or complicit in, or to have directly or indirectly engaged or attempted to engage in, any of the following:
(A) serious human rights abuse in Nicaragua;
(B) actions or policies that undermine democratic processes or institutions in Nicaragua;
(C) actions or policies that threaten the peace, security, or stability of Nicaragua;
(D) any transaction or series of transactions involving deceptive practices or corruption by, on behalf of, or otherwise related to the Government of Nicaragua or a current or former official of the Government of Nicaragua, such as the misappropriation of public assets or expropriation of private assets for personal gain or political purposes, corruption related to government contracts, or bribery;
(ii) has, or whose members have, engaged in any activity described in subsection (a) (i) of this section or of an entity whose property and interests in property are blocked pursuant to this order;
(iii) to be an official of the Government of Nicaragua or to have served as an official of the Government of Nicaragua at any time on or after January 10, 2007;
(iv) to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of:
(A) any activities described in subsection (a) (i) of this section; or
(B) any person whose property and interests in property are blocked pursuant to this order; or
As well as any entity implicated by the 50 Percent Rule…