The De­part­ment of the Trea­sury’s Of­fice of For­eign As­sets Con­trol (OFAC) Tues­day an­nounced that it had sanc­tioned mem­bers of one of Guyana’s wealth­i­est fam­i­lies, a Guyana gov­ern­ment of­fi­cial as well as a com­pa­ny for their roles in pub­lic cor­rup­tion in the Caribbean Com­mu­ni­ty (CARI­COM) coun­try.

In ad­di­tion to im­pos­ing the sanc­tions on Nazar Mo­hamed, his son, Azrud­din Mo­hamed, their com­pa­ny, Mo­hamed’s En­ter­prise, and gov­ern­ment of­fi­cial, Mae Thomas, OFAC has des­ig­nat­ed two oth­er en­ti­ties, Ha­di’s World and Team Mo­hamed’s Rac­ing Team, for be­ing owned or con­trolled by Mo­hamed’s En­ter­prise and Azrud­din, re­spec­tive­ly.

It said that these in­di­vid­u­als and en­ti­ties are sanc­tioned pur­suant to Ex­ec­u­tive Or­der13818, which builds up­on and im­ple­ments the Glob­al Mag­nit­sky Hu­man Rights Ac­count­abil­i­ty Act and tar­gets per­pe­tra­tors of se­ri­ous hu­man rights abuse and cor­rup­tion around the world.

“To­day’s ac­tion un­der­scores our com­mit­ment to hold­ing ac­count­able those who seek to ex­ploit Guyana’s un­der­de­vel­oped gold sec­tor for per­son­al gain,” said Un­der Sec­re­tary of the Trea­sury for Ter­ror­ism and Fi­nan­cial In­tel­li­gence Bri­an E. Nel­son.

“Trea­sury, in close co­or­di­na­tion with our part­ners in US law en­force­ment, will con­tin­ue to take ac­tion to safe­guard the U.S. fi­nan­cial sys­tem from abuse by cor­rupt ac­tors,” Nel­son added.

The OFAC ac­tions were con­duct­ed in co­or­di­na­tion with Home­land Se­cu­ri­ty In­ves­ti­ga­tions New York Or­ga­nized Crime Drug En­force­ment Task Force (OCDETF) Strike Force, Diplo­mat­ic Se­cu­ri­ty Ser­vice, Cus­toms and Bor­der Pro­tec­tion (CBP) Of­fice of In­tel­li­gence – New York Op­er­a­tions, and the Fed­er­al Bu­reau of In­ves­ti­ga­tion’s Mi­a­mi Field Of­fice, with as­sis­tance from HSI Mi­a­mi, CBP Mi­a­mi and New York Field Of­fices, New York City Po­lice De­part­ment In­tel­li­gence Bu­reau, and the Drug En­force­ment Ad­min­is­tra­tion.

The US au­thor­i­ties say gold is one of Guyana’s main ex­ports, but it re­mains a high­ly frac­tured in­dus­try with small-scale gold min­ing op­er­a­tions in Guyana oc­cu­py­ing a ma­jor­i­ty share of the coun­try’s gold pro­duc­tion.

It said these small, fam­i­ly-owned busi­ness­es have in­for­mal re­la­tion­ships with larg­er pur­chasers and traders like Mo­hamed’s En­ter­prise and that “once mined, Guyanese gold is sold and trad­ed through­out in­ter­na­tion­al mar­kets, in­clud­ing the Unit­ed States, Cana­da, the Unit­ed Arab Emi­rates, and the Eu­ro­pean Union.

It said that Nazar Mo­hamed found­ed Mo­hamed’s En­ter­prise in Guyana be­fore ex­pand­ing to the Unit­ed States as a mon­ey­chang­er and tran­si­tioned in­to gold trad­ing, grow­ing Mo­hamed’s En­ter­prise in­to one of Guyana’s largest gold ex­porters.

In time, Azrud­din Mo­hamed ul­ti­mate­ly took over Mo­hamed’s En­ter­prise, which al­so now does busi­ness as “Con­fi­den­tial Cam­bio.”

Azrud­din and Mo­hamed’s En­ter­prise evad­ed Guyana’s tax on gold ex­ports and de­fraud­ed the Guyanese gov­ern­ment of tax rev­enues by un­der de­clar­ing their gold ex­ports to Guyanese au­thor­i­ties. Be­tween 2019 and 2023, Mo­hamed’s En­ter­prise omit­ted more than 10 thou­sand kilo­grams of gold from im­port and ex­port de­c­la­ra­tions and avoid­ed pay­ing more than US$50 mil­lion in du­ty tax­es to the gov­ern­ment of Guyana.

“Mo­hamed’s En­ter­prise has bribed cus­toms of­fi­cials to fal­si­fy im­port and ex­port doc­u­ments, as well as to fa­cil­i­tate il­lic­it gold ship­ments. Mo­hamed’s En­ter­prise had paid bribes to Guyanese gov­ern­ment of­fi­cials to en­sure the undis­rupt­ed flow of in­bound and out­bound per­son­nel that move cur­ren­cy and oth­er items on be­half of Azrud­din and Mo­hamed’s En­ter­prise,” OFAC said.

It said to con­ceal their il­le­gal ac­tiv­i­ty and op­er­ate with im­puni­ty, “Azrud­din and Mo­hamed’s En­ter­prise have en­gaged in ex­ten­sive bribery schemes in­volv­ing gov­ern­ment of­fi­cials in Guyana.

“This in­cludes pro­vid­ing di­rect and re­cur­ring bribery pay­ments to Guyanese gov­ern­ment of­fi­cials to en­sure fa­vor­able treat­ment in crim­i­nal or civ­il mat­ters that would oth­er­wise sug­gest their in­volve­ment in il­le­gal crim­i­nal ac­tiv­i­ty. In re­turn, cor­rupt of­fi­cials re­ceive cash and gifts for in­ci­dents that are over­looked. Ad­di­tion­al­ly, Mo­hamed’s En­ter­prise has paid bribes to cor­rupt Guyanese gov­ern­ment of­fi­cials to fa­cil­i­tate the award of gov­ern­ment con­tracts.”

OFAC said that one such of­fi­cial, Mae Thomas, was the Per­ma­nent Sec­re­tary to Guyana’s Min­is­ter of Home Af­fairs from Oc­to­ber 2020 through Au­gust 2023, and is the cur­rent Per­ma­nent Sec­re­tary of the Min­istry of Labour.

“A cor­rupt Per­ma­nent Sec­re­tary could ma­nip­u­late pro­cure­ment process­es to suit their pre­ferred bid­der by pro­vid­ing in­side in­for­ma­tion at the ear­ly stages of eval­u­a­tion. Ac­cess to a Per­ma­nent Sec­re­tary of any Min­istry could af­ford con­trac­tors in­sight in­to up­com­ing projects and bid val­ues. Per­ma­nent Sec­re­taries can act as the le­gal au­thor­i­ty to sign con­tracts on be­half of their min­istry.”

OFAC said that while Per­ma­nent Sec­re­tary to Guyana’s Min­is­ter of Home Af­fairs, Thomas used her po­si­tion to of­fer ben­e­fits to Mo­hamed’s En­ter­prise and Azrud­din, among oth­ers, in ex­change for cash pay­ments and high-val­ue gifts.

“Thomas mis­used her po­si­tion to in­flu­ence the award of of­fi­cial con­tract bids and the ap­proval process­es for weapons per­mits and pass­ports on be­half of Mo­hamed’s En­ter­prise.

OFAC said as a re­sult of the 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, in­di­vid­u­al­ly or in the ag­gre­gate, 50 per cent or more by one or more blocked per­sons are al­so blocked. Un­less au­tho­rized by a gen­er­al or spe­cif­ic li­cense is­sued by OFAC, or ex­empt, OFAC’s reg­u­la­tions gen­er­al­ly pro­hib­it 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.”

In ad­di­tion, fi­nan­cial in­sti­tu­tions and oth­er per­sons that en­gage in cer­tain trans­ac­tions or ac­tiv­i­ties with the sanc­tioned en­ti­ties and in­di­vid­u­als may ex­pose them­selves to sanc­tions or be sub­ject to an en­force­ment ac­tion.

“The pro­hi­bi­tions in­clude the mak­ing of any con­tri­bu­tion or pro­vi­sion of funds, goods, or ser­vices by, to, or for the ben­e­fit of any des­ig­nat­ed per­son, or the re­ceipt of any con­tri­bu­tion or pro­vi­sion of funds, goods, or ser­vices from any such per­son.”its abil­i­ty to des­ig­nate and add per­sons to the SDN List, but al­so from its will­ing­ness to re­move per­sons from the SDN List con­sis­tent with the law.

“The ul­ti­mate goal of sanc­tions is not to pun­ish, but to bring about a pos­i­tive change in be­hav­iour”.