May 26, 2020

May 26, 2020

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U.S. Sanctions Individuals in Central African Republic

The White House has issued an Executive Order establishing a new sanctions regime targeting individuals deemed to be contributing to the severe instability in the Central African Republic (CAR). The new sanctions come a month after the U.S. Government’s implementation of a UN arms embargo issued earlier this year, which prohibits exports to the CAR of defense articles or defense services subject to the International Traffic in Arms Regulations (ITAR) in nearly all circumstances.

The CAR continues to suffer from widespread civil unrest, and there are growing reports of human rights violations, including apparent massacres of Muslim civilians committed by Anti-Balaka militias, stemming from a 2012 rebel uprising. In response to the violence, on May 13, 2014, the President issued an Executive Order establishing CAR-related sanctions. The new measures impose targeted sanctions on specific individuals, including the blocking (or freezing) of assets and visa bans for entry into the United States. The sanctions effectively prohibit U.S. persons from engaging in any transactions with the following five individuals:

  • Noureddine Adam (General and Former CAR Minister of Public Security)

  • Francois Bozize (Former CAR President)

  • Michel Djotodia (Former CAR Transitional President)

  • Abdoulaye Miskine (Leader of the Democratic Front of the CAR)

  • Levi Yakite (Anti-Balaka Political Coordinator)

In addition to the five newly-designated individuals listed above, the Executive Order also grants the Secretary of the Treasury authority to impose sanctions on additional individuals or entities deemed to contribute to instability in the CAR. The U.S. Government may therefore expand the list of sanctioned individuals in the coming months.

Given the deteriorating situation in the CAR, U.S. persons should exercise caution in dealings, direct and indirect, with all entities and individuals in or related to the CAR. Importantly, U.S. persons should conduct “party screening” of all entities in a proposed transaction against, at a minimum, the U.S. Department of the Treasury’s Specially Designated Nationals (SDN) List.

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About this Author

Kara Bombach, Greenberg Traurig, Washington DC, International Trade and White Collar Defense Attorney

Kara Bombach assists companies to lawfully export goods, technology and services around the globe. She places significant emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and OECD Convention), export control laws (EAR and ITAR), anti-boycott laws, and special sanctions (embargoes) maintained by the U.S. government (OFAC and other agencies) against various countries (including Iran, Cuba and Sudan), entities and individuals....

Cyril Brennan, Greenberg Traurig Law Firm, Washington DC, International Trade Law Attorney

Cyril (Cy) Brennan focuses his practice on international trade regulation and compliance, with an emphasis on U.S. export controls and economic sanctions. Cy handles matters regarding the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), U.S. sanctions programs administered by the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s anti-boycott regulations. In addition, he represents clients before the Committee on Foreign Investment in the United States (CFIUS), and advises clients on the Foreign Corrupt Practices Act (FCPA), the foreign direct investment reporting requirements of the Bureau of Economic Analysis (BEA), and other trade and investment-related regulations in the context of mergers and acquisitions.


  • Export controls and economic sanctions

  • Committee on Foreign Investment in the United States (CFIUS)

  • Anticorruption compliance

  • Foreign direct investment reporting

  • Regulatory due diligence

  • Foreign ownership, control or influence (FOCI)