New OFAC SDN Designations for Libya and Terrorism

The United States Department of the Treasury Office of Foreign Assets Control (OFAC) has recently designated two (2) individuals and 14 entities, under the Global Terrorism Sanctions and the Libya Sanctions respectively. The two individuals designated as Specially Designated Global Terrorists, Miguel De Garikota Aspiazu Rubina and Jose Ignacio Reta De Frutos, are both alleged to be linked to the Basque Fatherland and Liberty Organization. Mr. De Frutos is currently a fugitive from justice and Mr. De Garikota Aspiazu Rubina is currently detained in France.

As the United States and its allies continue their military campaign against Libya, OFAC is continuing to ramp up pressure on Libya via financial sanctions. OFAC’s latest actions correspond with the mandates of United Nations Security Council Resolution 1973 targeting the The National Oil Corporation in Libya. According to OFAC, the National Oil Corporation is the centerpiece of Libya’s state-owned oil apparatus, and maintains a network of companies involved in oil exploration, production, and sale.

Regardless of these new designations, the Libya Sanctions block all property and interests in property of the Government of Libya and its agencies, instrumentalities and controlled entities within U.S. jurisdiction, whether specifically identified by OFAC or not. As such, U.S. persons are prohibited from engaging in business with any Libyan state-owned entity. The aforementioned designations were made merely to assist financial institutions in meeting their obligations under the Libya Sanctions.

Treasury has openly stated that they will continue to monitor the National Oil Corporation’s operations in Libya and if ownership of either National Oil Corporation subsidiaries or facilities come under different ownership and control, Treasury may consider authorizing dealings with such entities.

This is great news for those in the market to buy a company involved the exploration, production or sale of oil. I would have to think that given the impact these sanctions will have on the designated parties to do business that the selling price would have to be fairly cheap. As such, right now its a buyer’s market for those looking to acquire oil businesses or facilities. Keep in mind, however, that before that company will be able to fully access the U.S. financial system, the OFAC SDN designation will need to be removed. As I have stated many times before the OFAC SDN Removal process can be a long hard road.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or

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