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U.S. DEPARTMENT OF THE TREASURY
OFFICE OF FOREIGN ASSETS CONTROL
STATEMENT ON THE SEIZURE OF SEGUROS CONTINENTAL S.A. BY THE GOVERNMENT OF HONDURAS
On October 7, 2015, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced the designation of Jaime Rolando Rosenthal Oliva, along with his son, Yani Benjamin Rosenthal Hidalgo, and his nephew, Yankel Antonio Rosenthal Coello, as Specially Designated Narcotics Traffickers pursuant to the Foreign Narcotics Kingpin Designation Act for providing money laundering and other services that support the international narcotics trafficking activities of multiple Central American drug traffickers and their criminal organizations. Also announced that day was the designation of seven of their companies pursuant to the Kingpin Act, including the designation of Inversiones Continental, S.A. de C.V. (also known as "Grupo Financiero Continental" or "Grupo Financiero"), which was sanctioned for being owned, controlled, or directed by,...
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1) Consolidated comment on Statement on the Seizure of Seguros Continental S.A. by the Government of Honduras; Statement on Proposed Liquidation of Banco Continental; Statement on the Felix Maduro Group.
These three OFAC "statements" all perform the same function, which is to assure non-U.S. persons not otherwise subject to the prohibitions of the FNKSR that dealings with the entities at issue will not be determined to constitute "[m]aterially assisting in, or providing financial or technological support for or to, or providing goods or services in support of, the international narcotics trafficking activities of a specially designated narcotics trafficker."
598.314 of the FNKSR provides for the possibility of designation upon a "material assistance" determination, which OFAC has stated may be based upon ordinary commercial dealings between parties...