Careers

Diversity, Equity & Inclusion

Experience

Innovation

Interactive Maps

Locations

About

Pages

Meet our team of innovators
Ask us how we do it

Professionals

Insights

Services

Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

Home | Thompson Hine LLP

Atlanta

Chicago

Cincinnati

Cleveland

Columbus

Dayton

Los Angeles

Minneapolis

New York

Silicon Valley

Washington, D.C.

Recent additions to the Specially Designated Nationals (SDN) List highlight an increasing enforcement focus on corruption and money laundering. On August 24, 2021, the Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) designated <a href="https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20210824" target="_blank" rel="noopener">three Paraguayan individuals and five associated entities</a> to the SDN List in response to a corruption and money-laundering scheme involving local and federal bureaucracies. OFAC noted that the Tri-Border Area (TBA) where Argentina, Brazil, and Paraguay converge &ldquo;is marked by a large number of unregistered money exchange houses, trade based money laundering through export-import and retail businesses in the electronics and automotive sectors, the lack of awareness of money laundering and terrorist financing typologies and risk in the private sector, the intensive use of cash by businesses and individuals, and a large volume of transfers to high risk jurisdictions.&rdquo; OFAC&rsquo;s Director, Andrea Gacki, stated that this action &ldquo;demonstrates the U.S. government&rsquo;s ongoing effort to impose tangible and significant consequences on corrupt actors in order to protect the U.S. financial system from abuse.&rdquo;
In this instance, three Paraguayan individuals, Kassem Mohamad Hijazi, Khalil Ahmad Hijazi, and Liz Paola Doldan Gonzalez, and five related entities connected to them were acting as &ldquo;despachantes&rdquo; (or dispatchers) in using their network of local and federal government officials to launder money. Through a network of front companies and business relationships, these individuals are able to move illicit proceeds &ldquo;all around the world with ease,&rdquo; including to the United States, South America, Europe, the Middle East, and China. For additional details on the overall scheme and role that each individual and front company played in the corruption and money laundering scheme, see OFAC&rsquo;s <a href="https://home.treasury.gov/news/press-releases/jy0332" target="_blank" rel="noopener">press release</a>.
As a result of these designations to the SDN List, all property and interests in property of these individuals and entities that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. U.S. persons are generally prohibited from engaging in transactions with these sanctioned individuals and entities. In addition, any entities that are owned, directly or indirectly, 50 percent or more by the designated persons and entities are also blocked.

core/freeform

SmarTrade

Senior Legislative and Regulatory Policy Advisor

Scott E. Diamond

International Trade

OFAC Sanctions Paraguayan Individuals and Entities for Money Laundering and Corruption   