The Mali sanctions target individuals and entities responsible for, complicit in or engaged in activities that threaten the peace, security, stability or democratic processes and institutions of Mali. Any individuals designated for their involvement in such activities shall be:
- subject to an “asset freeze”, blocking all property and interests in property that are in the United States or come within the United States or into the possession or control of a U.S. person; and
- banned from entry into the United States unless their entry is recommended by the U.S. Attorney General.
The new sanctions prohibit U.S. persons from engaging in virtually all transactions with individuals and entities that have been designated under this E.O. without authorization from the Office of Foreign Assets Control (“OFAC”). Additionally, non-U.S. persons determined “to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of any person whose property and interests in property are blocked pursuant to this” E.O. can also be designated.
Both U.S. and non-U.S. persons doing business in Mali should therefore take care to ensure that neither counterparties, nor other parties related to their business, are designated by OFAC (or other sanctions authorities). At the time of writing, there are nine Malian persons (four entities and five individuals) designated by OFAC pursuant to other sanctions authorities. Given the introduction of the new E.O., however, we would expect this number to increase.