Introduction
1. The Global Anti-Corruption Sanctions Regulations 2021 (the “UK Regulations”) provide for the freezing of funds and economic resources of certain persons or entities to prevent and combat serious corruption.
2. The Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021 (the “Order”), made under the Sanctions and Asset-Freezing (Jersey) Law 2019 (“SAFL”), links to the UK Regulations.
3. Any asset-freeze designations made under the UK Regulations are effective immediately by virtue of the ambulatory provisions in Jersey’s sanctions legislation.
4. An asset freeze now applies to the persons listed in the Annex to this Notice under Part 3 of SAFL.
Notice summary (Full details are provided in the Annex to this Notice)
5. The following designations have been made and are now subject to an asset freeze:
- Nawfal Hammadi AL-SULTAN
- Teodoro NGUEMA OBIANG MANGUE
- Alvaro Enrique PULIDO VARGAS
- Alex Nain SAAB MORAN
- Kudakwashe Regimond TAGWIREI
What you must do
6. You must:
- check whether you maintain any accounts or hold any funds or economic resources for the persons set out in the Annex to this Notice.
- freeze such accounts, and other funds or economic resources.
- refrain from dealing with the funds or assets or making them available (directly or indirectly) to such persons unless licensed by the Minister for External Relations and Financial Services (“MERFS”).
- report any findings to MERFS, together with any additional information that would facilitate compliance with SAFL.
- provide any information concerning the frozen assets of designated persons that MERFS may request. Information reported to MERFS may be passed on to other regulatory authorities or law enforcement.
7. Failure to comply with sanctions legislation or to seek to circumvent its provisions is a criminal offence.
Further Information
9. Jersey guidance on the Anti-corruption sanctions regime is available on
JFSC website (listed under UK Global Anti-corruption).
10. Copies of Jersey sanctions legislation, including the
Order and
SAFL, can be found on the Jersey Legal Information Board website.
11. A copy of the UK Regulations can be obtained from
legislation.gov.uk and other relevant information about this regime can be found on
gov.uk.
12. A copy of the UK sanctions list can be found
here.
13. A copy of the OFSI consolidated list can be found here.
Enquiries
14. Non-media enquiries, suspected breach reports and licence applications should be addressed to:
Head of International Compliance
Office of the Chief Executive
External Relations
sanctions@gov.je
ANNEX TO NOTICE
FINANCIAL SANCTIONS: ANTI-CORRUPTION
ADDITIONS
Individuals
1. AL-SULTAN, Nawfal Hammadi
DOB: 23/02/1964. POB: Iraq a.k.a: (1) AGUB, Nofal (2) AKOUB, Nawfel (3) AL-AKOUB, Nawfel (4) AL-SULTAN, Nofal, Hammadi (5) SULTAN ALBU HAMAD, Nofal, Hammadi (6) SULTAN YOUSEF, Nawfal, Hamadi (7) SULTAN YOUSIF ALBOHAMAD, Nawful, Humadi Nationality: Iraq National Identification no: 71719043 Address: Iraq. Other Information: (UK Sanctions List Ref):GAC0027 (UK Statement of Reasons): Nawfal Hammadi Al-Sultan has been involved in serious corruption in Nineveh province, Iraq involving the misappropriation of state property to his benefit and the benefit of others. In his role as governor of Nineveh province, he misappropriated public funds intended for reconstruction efforts and to provide support for civilians and improperly awarded contracts and other state property. Additional information: in February 2021 Al-Sultan was convicted by the Central Anti-Corruption Criminal Court in Iraq in relation to some of his corrupt activities when governor of Nineveh Governorate. He was convicted of two offences of “harming a public body” under Article 340 of Iraq’s Penal Code and sentenced to a total of five years in prison, for: (i) wasting five billion Iraqi Dinars of public funds of Nineveh Governorate through fictitious works and contracts, and (ii) improperly disposing of 50 tons of asphalt delivered to him for paving the streets and for reconstruction in 2017. (Gender): Male Listed on: 22/07/2021 Last Updated: 22/07/2021
2. NGUEMA OBIANG MANGUE, Teodoro
Title: Vice President DOB: 25/06/1968. POB: Malabo, Equatorial Guinea a.k.a: TEODORIN Nationality: Equatorial Guinea Address: Malabo, Equatorial Guinea. Position: Vice President Other Information: (UK Sanctions List Ref):GAC0024 (UK Statement of Reasons): Teodoro Nguema Obiang Mangue has been involved in the misappropriation of significant amounts of public assets from Equatorial Guinea as well as bribery, to fund a lavish lifestyle in various countries abroad including the United States and France, where he held assets which were vastly disproportionate in value by comparison to his official salary as an Equatorial Guinean government minister. (Gender): Male Listed on: 22/07/2021 Last Updated: 22/07/2021
3. PULIDO VARGAS, Alvaro Enrique
DOB: 10/12/1963. POB: Bogota, Colombia a.k.a: (1) CUCHI (2) RUBIO SALAS, German, Enrique Nationality: Colombia Passport Details: PE069914 (Columbia) National Identification no: 79324956 (Columbia) Other Information: (UK Sanctions List Ref):GAC0026 (UK Statement of Reasons): Alvaro Enrique Pulido Vargas (aka German Enrique Rubio Salas) is a close business associate of Alex Saab. With him, he engaged in serious corruption in Venezuela through his participation in two of Venezuela’s public programmes: the ‘Local Committees for Supply and Production’ (CLAP) and the Great Housing Scheme Venezuela (GMVV). In each case, contracts were improperly granted for the benefit of an official and/or for another person including Pulido Vargas himself. In the CLAP programme, basic foodstuffs were provided at highly inflated prices. For GMVV, Global Construction Fund only delivered a small proportion of the products they had agreed to deliver, misappropriating the remainder of the funds. (Gender): Male Listed on: 22/07/2021 Last Updated: 22/07/2021
4. SAAB MORAN, Alex Nain
DOB: 21/12/1971. POB: Barranquilla, Colombia Nationality: (1) Colombia (2) Venezuela Passport Details: (1) PE085897 (Columbia) (2) 085635076 (Venezuela) National Identification no: (1) 72180017 (Columbia) (2) 21.495.350 (Venezuela) Address: Cape Verde. Other Information: (UK Sanctions List Ref):GAC0025 (UK Statement of Reasons): Alex Nain Saab Moran engaged in serious corruption in Venezuela through his participation in two of Venezuela’s public programmes: the ‘Local Committees for Supply and Production’ (CLAP) and the Great Housing Scheme Venezuela (Spanish acronym: GMVV). In each case, contracts were improperly granted by public officials to companies owned or controlled by Saab Moran, for the benefit of the official(s) and/or for another person, including Saab Moran himself. In the CLAP programme, basic foodstuffs were provided at highly inflated prices. For GMVV, Saab Moran’s company only delivered a small proportion of the products they had agreed to deliver and for which it had been paid, misappropriating the remainder of the funds. (Gender): Male Listed on: 22/07/2021 Last Updated: 22/07/2021
5. TAGWIREI, Kudakwashe Regimond
DOB: 12/02/1969. POB: Shurugwi, Zimbabwe a.k.a: KUDA Nationality: (1) Zimbabwe (2) South Africa Passport Details: (1) FN920256 (Zimbabwe) (2) EN183928 (Zimbabwe) (3) VUK491921 (Canada) National Identification no: 29135894Z66 Address: 4 Luna Road, Borrowdale, Harare, Zimbabwe. Other Information: (UK Sanctions List Ref):GAC0023 (UK Statement of Reasons): Kudakwashe Regimond Tagwirei profited or otherwise benefitted from the misappropriation of property when his company, Sakunda Holdings, redeemed Government of Zimbabwe Treasury Bills at up to ten times their official value. This meant that Sakunda Holdings and Tagwirei, as its CEO and owner, profited significantly at the expense of macroeconomic stability in Zimbabwe. (Gender):Male Listed on: 22/07/2021 Last Updated: 22/07/2021
Ministry of External Relations
22 July 2021
gov.je