On December 9, 2021, the Office of Foreign Assets Control (OFAC) announced sanctions on two individuals for corruption involving procurement during the pandemic. The Department of the Treasury stated that “Corruption involving procurement of life-saving medical supplies represents a profound betrayal of public trust and a waste of critically needed resources.” Government officials in El Salvador and Guatemala were sanctioned for allegedly being involved in suspicious procurement, directing suspicious pandemic-related purchases, reselling personal protective equipment and other medial aid at significant markup and for personal gain, and/or for favoring companies where family members were officers. The actions continue the use of the Global Magnitsky sanctions to target global corruption and the inter-agency focus of the U.S. government on pandemic-related fraud.

The OFAC announcement also identifies individuals and entities in several other countries in Central America, Africa, and Europe for various other corrupt practices. As a result of these sanctions, all property and interests in property of the designated persons that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more designated persons are also blocked. Unless authorized by a license or exemption, all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons are prohibited.