On 24 August, OFAC advised that 2 Paraguayans and a Brazilian have been added to the OGAC Global Magnitsky sanctions lists for human rights abuses.  5 companies in Paraguay have also been designated.  The US Treasury says that this action highlights the illicit finance risks and activities in the Tri-Border Area (TBA) where Argentina, Brazil, and Paraguay converge.  It says that this region 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.  The action targets the so-called Hijazi network, a form of the despachantes (“dispatchers”), individuals skilled at navigating local and federal bureaucracies by using their expansive networks of government officials to aid them in their activities.  Complex government bureaucracies in the area are coupled with a lack of transparency and accountability  


The full, current SDN (sanctions) lists can be accessed at –


Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at https://www.buymeacoffee.com/KoIvM842y

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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