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OFAC Nicaragua updates: new E.O., new designations, new General License, new FAQ

First, the new Executive Order:

Next, the new person:

CERNA JUAREZ, Reinaldo Gregorio Lenin (a.k.a. CERNA JUAREZ, Lenin), Nicaragua; DOB 29 Sep 1947; alt. DOB 29 Sep 1946; POB Nicaragua; nationality Nicaragua; citizen Nicaragua; Gender Male; Passport A005297 (Nicaragua) (individual) [NICARAGUA]. 

and entity:

GENERAL DIRECTORATE OF MINES (Latin: DIRECCIÓN GENERAL DE MINAS), Barrio Largaespada, Hospital Bautista 1c Oeste 1c Norte, Managua, Nicaragua; Organization Type: Mining of other non-ferrous metal ores; Target Type State-Owned Enterprise [NICARAGUA] (Linked To: MANSELL CASTRILLO, Salvador). 

added to the Nicaragua sanctions program.

Third, the new General License 4. It permits wind-down activities with the Directorate General of Mines of the Nicaraguan Ministry of Energy and Mines, and expires November 23.

Fourth, the new Frequently Asked Question (FAQ):

1093. What does Nicaragua General License (GL) 4 authorize?


Nicaragua GL 4  authorizes U.S. persons to engage in transactions prohibited by the Nicaragua Sanctions Regulations, 31 CFR part 582 (the NSR), that are ordinarily incident and necessary to the wind down of any transaction involving the Directorate General of Mines (DGM) of the Nicaraguan Ministry of Energy and Mines, or any entity in which DGM owns, directly or indirectly, a 50 percent or greater interest (collectively, “Blocked DGM Entities”), through 12:01 a.m. eastern standard time, November 23, 2022, provided that any payment to a blocked person must be made into a blocked account in accordance with the NSR.

After the expiration of this authorization, unless exempt or authorized by the Office of Foreign Assets Control, U.S. persons will be prohibited from engaging in transactions with the Blocked DGM Entities and must block property or interests in property of any Blocked DGM Entities that are in, or thereafter come within, the United States, or the possession or control of a U.S. person.

Non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under the NSR for engaging in transactions with blocked persons where those transactions would not require a specific license if engaged in by a U.S. person. 

FAQ 1093

And the Treasury:


Treasury Sanctions Nicaragua Directorate of Mines and Government Official Responsible for Decades of Violence 

October 24, 2022

New Executive Order Targets Nicaraguan Gold Sector, Other Sectors May Follow

WASHINGTON — Today, the U.S. Department of the Treasury (Treasury) Office of Foreign Assets Control (OFAC) designated the Nicaraguan mining authority General Directorate of Mines (DGM) as well as one official of the Government of Nicaragua, pursuant to Executive Order (E.O.) 13851.

Additionally, today President Biden signed a new E.O. that amends E.O. 13851 and expands Treasury’s authority to hold the Ortega-Murillo regime accountable for its continued attacks on Nicaraguans’ freedom of expression and assembly. Furthermore, the new E.O. gives Treasury the authority to target certain persons that operate or have operated in the gold sector of the Nicaraguan economy, and any other sector identified by the Secretary of the Treasury in consultation with the Secretary of State. The new E.O. also provides expanded sanctions authorities that could be used to prohibit new U.S. investment in certain identified sectors in Nicaragua, the importation of certain products of Nicaraguan origin into the United States, or the exportation, from the United States, or by a United States person, wherever located, of certain items to Nicaragua.

“The Ortega-Murillo regime’s continued attacks on democratic actors and members of civil society and unjust detention of political prisoners demonstrate that the regime feels it is not bound by the rule of law,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “With President Biden’s new Executive Order, we can and will use every tool at our disposal to deny the Ortega-Murillo regime the resources they need to continue to undermine democratic institutions in Nicaragua.” 


DGM is a subordinate office within the Nicaraguan Ministry of Energy and Mines (MEM). Since the June 2022 designation of Empresas Nicaraguenses de Minas (ENIMINAS), DGM has managed most mining operations in Nicaragua on behalf of the Nicaraguan government. As such, DGM is an important piece of state-controlled gold operations in Nicaragua. Ortega and his cronies continue to use proceeds derived from the production and sale of gold to line their own pockets and to pay off those who keep the regime in power. The regime has used this power to intimidate and jail those that speak out about the regime’s corruption and to sow instability around the world, including by supporting Russia’s further invasion of Ukraine. By designating DGM, Treasury aims to cut off the Ortega-Murillo regime from its ability to use gold proceeds to oppress the Nicaraguan people.

DGM is being designated for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Salvador Mansell Castrillo, who is the Nicaraguan Minister of Energy and Mines and whose property and interests in property were blocked pursuant to E.O. 13851 on November 15, 2021. Today, OFAC also issued Nicaragua General License (GL) 4, which provides a time-limited authorization allowing U.S. persons to wind down transactions involving DGM. OFAC also issued associated guidance noting that foreign persons generally do not risk sanctions for engaging in activities that would be authorized by GL 4.


Cerna is a close confidante of Nicaraguan President Daniel Ortega. He was head of state security under the first Ortega presidency in the 1970s and 1980s and was reportedly involved in numerous incidents of violence, murder, and torture and admitted to associating with known terrorist groups. Cerna previously worked at the Consulate of Nicaragua in Honduras and allegedly helped in the assassination of Pablo Emilio Salazar, head of the presidential guard for then president Anastasio Somoza Debayle. Cerna allegedly provided the weapon that killed Salazar. Once he took over as head of State Security under Ortega, according to public reporting, Cerna became renowned and feared as a torturer.

Cerna is being designated, pursuant to E.O. 13851, for being an official of the Government of Nicaragua or having served as an official of the Government of Nicaragua at any time on or after January 10, 2007.


As a result of today’s action, all property and interests in property of these 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. In addition, any entities that are owned, directly or indirectly, 50 percent or more in the aggregate by one or more of such persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked or designated persons are prohibited, unless authorized by a general or specific license issued by OFAC, or otherwise exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any person whose property and interests in property are blocked pursuant to E.O. 13851 and the receipt of any contribution or provision of funds, goods, or services from any such person.

The power and integrity of OFAC sanctions derive not only from its ability to designate and add persons to the SDN List, but also from OFAC’s willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 For detailed information on the process to submit a request for removal from an OFAC sanctions list.

U.S. Treasury Department Press Release

and State Departments:

Expanding U.S. Sanctions Authorities and Announcement of Visa Restrictions for Nicaraguan Officials



OCTOBER 24, 2022

Today, we are announcing steps to impose visa restrictions on over 500 Nicaraguan individuals and their family members.  We are doing so pursuant to Presidential Proclamation 10309, which suspends entry into the United States as immigrants and nonimmigrants of members of the Government of Nicaragua and other persons who formulate, implement or benefit from policies or actions that undermine democratic institutions or impede the return to democracy in Nicaragua.  These individuals include members of Nicaraguan security services, such as the Nicaraguan National Police, penitentiary officials, judges, prosecutors, higher education officials and non-government actors who enable regime repression and corruption as well as their family members.  No member of the Nicaraguan government nor anyone who facilitates the Ortega-Murillo regime’s abuses should believe they can travel freely to the United States.

The White House also announced an amendment to Executive Order (E.O.) 13851 on Nicaragua that expands sanctions authorities, including specific trade-related measures for Nicaragua. These new authorities will support our efforts to hold the Ortega-Murillo regime accountable.  The regime’s accelerating actions this year closing space for civil society, increasing its security cooperation with Russia, and silencing independent voices despite broad international calls for dialogue and moderation compel the United States to act.  Governments that deny their people’s basic rights or threaten the security interests of their neighbors should not expect that their political, economic, and trade relationships will remain unaffected.

In conjunction with the E.O. announcement, the U.S. Department of the Treasury’s Office of Foreign Assets Control imposed sanctions on Nicaraguan mining authority General Directorate of Mines, an office in the Ministry of Energy and Mines, and Reinaldo Gregorio Lenin Cerna Juarez, a close confidante of Nicaraguan President Ortega, pursuant to E.O. 13851.

The United States, together with our allies and partners, believes that a return to democracy and respect for human rights and fundamental freedoms in Nicaragua is essential.  We will use diplomatic and economic tools available to promote accountability for the Ortega-Murillo regime, reiterate our call for the immediate and unconditional release of political prisoners, and urge the restoration of civic space for the people of Nicaragua.

U.S. State Department Press Release

both issued press releases, and the White House released a Fact Sheet:

FACT SHEET: Biden-⁠Harris Administration Expands Efforts to Hold Nicaraguan Government Accountable

  1. HOME

Today, President Biden is taking further action to demonstrate our commitment to the Nicaraguan people by expanding the tools to hold the Ortega-Murillo regime accountable for its escalating human rights violations, continued dismantling of democratic institutions, attacks on civil society, and increasing security cooperation with Russia. 

President Biden signed an Executive Order (E.O.) that amends E.O. 13851 (Blocking Property of Certain Persons Contributing to the Situation in Nicaragua) to expand the authorities available to increase targeted pressure on the Ortega-Murillo regime. This will give the Administration additional means to target the regime while allowing the flexibility necessary to continue to support the people of Nicaragua.

In the lead up to Nicaragua’s November 2021 sham elections, the Ortega-Murillo regime arbitrarily detained dozens of political opponents and pro-democracy activists. Since then, the limited remaining democratic space in the country has shrunk even further as the Ortega-Murillo regime shuttered over 2,000 non-governmental organizations and subjected political prisoners to extremely harsh conditions. And, the Nicaraguan regime has increased its attacks on faith leaders and closed private universities, robbing Nicaragua’s youth of their future and politicizing education. 

While the United States and our allies continue to take steps to hold Russia accountable for its war of aggression in Ukraine, the Ortega-Murillo regime has increased its cooperation with Moscow by authorizing the continued presence of Russian military personnel and equipment in the country. The regime was one of only four countries — and the only country in Latin America — to vote with Russia against an October 2022 United Nations General Assembly resolution condemning its attempted illegal annexation of parts of Ukraine.

The Biden-Harris Administration is today taking the following actions:

  • Today’s amended E.O. substantially expands our Nicaragua sanctions program with sectoral sanctions authorities, which expose individuals and entities operating in identified sectors to sanctions. Specifically, the amended E.O. identifies the gold sector of the Nicaraguan economy, which the Ortega-Murillo regime uses to fund its authoritarian and destabilizing activities. The E.O. also allows for the future identification of additional sectors that could become subject to sanctions, if warranted.
  • The amended E.O. adds new authorities to allow for the imposition of future restrictions on certain trade with Nicaragua to limit the outsized financial benefits of certain trade from flowing to the Ortega-Murillo regime, as warranted. This could potentially include restrictions on both imports into the United States from Nicaragua and exports from the United States to Nicaragua. 
  • The amended E.O. also authorizes certain restrictions on new investment in sectors of the Nicaraguan economy to prevent the United States from contributing to the corrupt regime’s coffers.   
  • Concurrent with this action, the Department of the Treasury is designating a key Nicaraguan entity that is central to the mining sector that directly benefits the Ortega-Murillo regime, as well as an individual linked to major human rights abuses in the country.
  • To continue supporting the Nicaraguan people and hold those who support the corrupt Nicaraguan Government accountable, the State Department is imposing visa restrictions on more than 500 Nicaraguan individuals, and their family members, who work for the Nicaraguan Government or formulate, implement, or benefit from policies or actions that undermine or injure democratic institutions or impede the return to democracy in the country.

Today’s actions build on recent efforts by the Biden-Harris Administration to support the Nicaraguan people and hold the Ortega-Murillo regime accountable. This includes the designation of Nicaragua’s state mining company, ENIMINAS in June 2022, and the reallocation of the country’s sugar quota by the Office of the U.S. Trade Representative in July 2022.

White House Fact Sheet


OFAC Notice

Executive Order

General License 4

New Frequently Asked Question (FAQ)

Press Releases – Treasury, State

White House Fact Sheet

Categories: Executive Orders Frequently Asked Questions (FAQ) Guidance Licenses Nicaragua sanctions OFAC Updates Sanctions Lists White House updates Wind Down Activities


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