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The Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury has reaffirmed that non-U.S. persons could also face sanctions if they provide material support to individuals or entities already subject to U.S. restrictions. The clarification was recently communicated in correspondence shared by representatives of a sanctioned business family (U.S. Department of the Treasury).
According to OFAC, unless exempted or licensed, U.S. persons are prohibited from engaging in transactions with sanctioned individuals or companies. Non-U.S. persons, while outside U.S. jurisdiction, also face exposure to sanctions if their activities are deemed to involve material support to designated parties. This principle reinforces the broad reach of U.S. financial regulations in targeting money laundering, corruption, and related activities (OFAC Guidance).
The sanctions in question were imposed in June 2024, covering specific individuals and their affiliated businesses in connection with alleged gold smuggling and corruption. Following the announcement, Guyanese authorities rescinded the affected businesses’ licences, while several local and international banks moved to close associated accounts to ensure compliance with Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) standards (Government of Guyana).
The issue has gained renewed attention as a political organisation led by a member of the sanctioned family prepares to contest the September 2025 general and regional elections. Several candidates of the party have also reported bank account closures, citing concerns over their association with sanctioned individuals. In response, OFAC clarified that while sanctions do not extend to individuals solely for their association, banks and other entities retain discretion to apply their own compliance measures (OFAC Guidance).
Local financial institutions have pointed to their obligations under international banking regulations, particularly regarding “politically exposed persons” (PEPs), who are subject to enhanced scrutiny due to potential risks of illicit financial activity. Party representatives, however, have described the closures as politically motivated and have threatened legal action against the institutions involved (Department of Public Information).
The situation has been further complicated by reports of interactions between members of the sanctioned family and the Venezuelan Embassy in Georgetown. Given the ongoing territorial dispute between Guyana and Venezuela, these developments have prompted close attention from both domestic and international observers (Ministry of Foreign Affairs).
The matter underscores the far-reaching implications of U.S. sanctions policy, the compliance challenges for local institutions, and the heightened scrutiny placed on political and financial activities in Guyana’s evolving landscape (U.S. Department of the Treasury).
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OFAC Reiterates Sanctions Risks for Non-U.S. Persons Supporting Designated Individuals
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