On September 5, OFAC issued regulations to implement Executive Order (EO) 13851 related to the situation in Nicaragua.  Signed on November 27, 2018, EO 13851 blocks the property of persons who served as Nicaraguan government officials at any time on or after January 10, 2007, persons who are responsible or complicit in serious human rights abuses, undermining democracy, threatening peace and security, or corruption and expropriation.  It also blocks leaders or officials of entities that have engaged in such practices, as well as entities owned by persons blocked by the EO.

EO 13851 does not restrict general exports or imports involving Nicaragua.  Rather it is targeted at prohibiting US persons from engaging in transactions with designated persons and entities, and any undesignated entities that are owned 50 percent or more by one or more designated entities or persons.

The order also authorizes the US government to block the property of any persons, including non-U.S. persons, that materially assist, or provide financial, material, or technological support for, or goods or services in support of, persons and entities blocked by the order, as well as persons that provide support for human rights abuses, threats to peace and security, corruption and other activities described in the order.
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