OFAC Issues Africa Gold Advisory

On June 27, 2023, the Treasury Department's Office of Foreign Assets Control ("OFAC"), in conjunction with USAID, and the Departments of Commerce, Homeland Security, and Labor, published an Africa Gold Advisory identifying risks related to the gold industry. At the same time, OFAC added several entities in the industry to its list of Specially Designated Nationals and Blocked Persons ("SDNs") for their connections to and support of the Russian mercenary group, the Wagner Group, and its leader, Yevgeny Prigozhin. The Advisory highlights the sanctions, corruption, and other key risks associated with the gold industry and provides guidance on how to mitigate those risks.

U.S. parties with business in Africa's gold industry face heightened risk of a counterparty being designated as an SDN, particularly given the Advisory and recent SDN designations. As a reminder, SDNs are subject to "blocking sanctions," meaning that U.S. persons are broadly prohibited from