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3/19/2020

Treasury Sanctions Corruption and Material Support Networks | U.S. Department of the Treasury

Treasury Sanctions Corruption and Material Support Networks
December 9, 2019

Global Magnitsky and Venezuela designations target corruption on International AntiCorruption Day
Washington – Corruption is a global problem. It undermines the abilities of governments to
adequately care for their citizens; erodes the legal, moral, and ethical fabric of society; and
facilitates transnational crime. Today, on International Anti-Corruption Day, the U.S.
Department of the Treasury’s O ice of Foreign Assets Control (OFAC) is targeting corrupt actors
and their networks across numerous countries in Europe, Asia, and Latin America. Today’s
action, pursuant to Executive Order (E.O.) 13818, which builds upon and implements the Global
Magnitsky Human Rights Accountability Act, and targets perpetrators of serious human rights
abuse and corruption. Additionally, two corrupt Venezuelan o icials were also designated
today, pursuant to Venezuela E.O. 13692, as amended, in light of their senior leadership roles in
the Maduro regime.
“Corruption deprives people of their countries’ resources, basic essential services, and
economic opportunities, while it enriches a select few and facilitates environmental destruction
political instability, and conflict,” said Secretary Steven T. Mnuchin. “On International AntiCorruption Day, we are targeting actors in Europe, Asia, and Latin America who continue
through their illicit activities to undermine the foundations of stable, secure, and functioning
societies.”
To raise public awareness for anti-corruption initiatives, International Anti-Corruption day has
been observed annually on December 9 since the United Nations General Assembly adopted the
United Nations Convention against Corruption (UNCAC) on October 31, 2003. Currently UNCAC
has 186 State parties.
AIVARS LEMBERGS
Corruption has undermined the Latvian economy for years, robbing the Latvian people of funds
for public services, and empowering illicit actors to harm the security of the Latvian state and
the NATO Alliance. The United States has worked closely with the Government of Latvia to
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address corruption there and elsewhere and are committed to our common cause. This U.S.
action underscores the U.S. commitment to Latvia and our determination to hold corrupt
oligarchs accountable for their actions against a key European ally.
Latvian oligarch Aivars Lembergs (Lembergs) is designated for being a foreign person who is a
current or former government o icial responsible for or complicit in, or directly or indirectly
engaged in, corruption, including the misappropriation of state assets, the expropriation of
private assets for personal gain, corruption related to government contracts or the extraction of
natural resources, or bribery.
Lembergs has served as the Mayor of Ventspils, Latvia, since 1988. From that time, he has been
repeatedly accused of money laundering, bribery, and abuse of o ice. Lembergs controls
entities through political parties and corrupt politicians, and systematically exploits those
entities and individuals for his own economic gain. Lembergs has used his influence over
leadership of political parties to shape government personnel and place certain government
o icials in positions, as well as to obstruct other government o icials from obtaining leadership
positions. Additionally, Lembergs has leveraged and corrupted law enforcement o icials to
protect his interests and subvert politicians whom he otherwise was unable to control.
In addition to designating Lembergs, OFAC is designating four Latvia-based entities that are
owned or controlled by him: Ventspils Freeport Authority, Ventspils Attistibas Agentura
(also known as Ventspils Development Agency), Biznesa Attistibas Asociacija (also known as
Business Development Association), and Latvijas Tranzita Biznesa Asociacija (also known as
Latvian Transit Business Association).
In connection with these designations, OFAC simultaneously issued Global Magnitsky General
License No. 1, which authorizes certain transactions and activities that are ordinarily incident
and necessary to the wind down of transactions involving Ventspils Freeport Authority, Ventspils
Attistibas Agentura, Biznesa Attistibas Asociacija, or Latvijas Tranzita Biznesa Asociacija, or any
entity in which one or more of the designated entities owns, directly or indirectly, a 50 percent
or greater interest, for a 30-day period.
TRY PHEAP
Try Pheap (Pheap) is designated for being a foreign person who is a current or former
government o icial responsible for or complicit in, or directly or indirectly engaged in,
corruption, including the misappropriation of state assets, the expropriation of private assets for
personal gain, corruption related to government contracts or the extraction of natural resources,
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or bribery. The United States prioritizes anticorruption e orts as a key part of its vision for a free
and open Indo-Pacific, recognizing good governance as integral to U.S. foreign policy and
national security interests and in line with U.S. values.
Pheap has used his vast network inside Cambodia to build a large scale illegal logging
consortium that relies on the collusion of Cambodian o icials, to include purchasing protection
from the government, including military protection, for the movement of his illegal products.
For example, Pheap used the Cambodian military to enable his timber tra icking activities and
sell to buyers in Vietnam, China, Europe, and Russia. The support of these o icials makes it
di icult for local authorities to take lawful action against Pheap, as in one example, Cambodian
National Park o icials were paid by Pheap to keep his operations secret from the international
community.
In addition to the designation of Pheap, OFAC is designating 11 Cambodia-registered entities
that are owned or controlled by Pheap: Try Pheap Group Co., Ltd.; M.D.S. Import Export Co.,
Ltd.; Try Pheap Dry Port Co., Ltd.; Try Pheap Engineering & Construction Co., Ltd.; Try
Pheap Grand Royal Co., Ltd.; Try Pheap Import Export Co., Ltd.; Papa Petroleum Co., Ltd.;
Try Pheap Property Co., Ltd.; Try Pheap Travel & Tours Co., Ltd.; M D S Thmorda S E Z Co.,
Ltd.; and Try Pheap Oyadav S E Z Co., Ltd.
KUN KIM AND HIS FAMILY NETWORK
Kun Kim (Kim) is designated for being a foreign person who is a current or former government
o icial responsible for or complicit in, or has directly or indirectly engaged in corruption,
including the misappropriation of state assets, the expropriation of private assets for personal
gain, corruption related to government contracts or the extraction of natural resources, or
bribery.
Kim was a senior General in the RCAF and was instrumental in a development in Koh Kong
province and had reaped significant financial benefit from his relationships with a People’s
Republic of China (PRC) state-owned entity. Kim used RCAF soldiers to intimidate, demolish,
and clear-out land sought by the PRC-owned entity. Kun Kim was replaced as RCAF Chief of
Sta because Kim had not shared profits from his unlawful businesses with senior Cambodian
government o icials.
Cambodian elites like Kim use their familial networks to create shadow structures to shield illgotten assets. Such corruption undermines the ability to realize the vision for a free and open
Indo-Pacific that we share with ASEAN and other Indo-Pacific partners. In addition to Kim, OFAC
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designated three members of Kim’s family: King Chandy (Chandy), Kim Sophary (Sophary),
and Kim Phara (Phara), for acting or purporting to act for or on behalf of, directly or indirectly,
Kim. Five entities that are owned or controlled by these individuals were also designated today:
• 7 Makara Phary Co., Ltd. is registered in Cambodia, and is owned or controlled by Sophary.
• K D Rubber Plantation Co., Ltd. is registered in Cambodia, and is owned or controlled by
Chandy.
• Cambo Elite Security Force Co., Ltd. is registered in Cambodia, and is owned or controlled by
Sophary.
• Romdoul Capital Pawn Co., Ltd. and Romdoul Development Co., Ltd. are registered in
Cambodia, and are owned or controlled by Phara.
SLOBODAN TESIC’S MATERIAL SUPPORT NETWORK
Slobodan Tesic (Tesic) was identified in the annex of E.O. 13818 on December 21, 2017. At the
time of his designation, Tesic was among the biggest dealers of arms and munitions in the
Balkans, spending nearly a decade on the United Nations (UN) Travel Ban List for violating UN
sanctions against arms exports to Liberia. In order to secure arms contracts with various
countries, Tesic would directly or indirectly provide bribes and financial assistance. Tesic took
potential clients on high-value vacations, paid for their children’s education at western schools
or universities, and used large bribes to secure contracts. Four companies were concurrently
designated for being owned or controlled by Tesic: Preduzece Za Trgovinu Na Veliko I Malo
Partizan Tech DOO Beograd-Savski Venac (Partizan Tech), Technoglobal Systems DOO
Beograd (Technoglobal), Charso Limited, and Grawit Limited.
Following his designation, Tesic continued to engage in the arms trade and operate as a silent
partner in companies he indirectly owns and manages. In these instances, Tesic still controls
many, if not all, aspects of the companies’ daily operations, including brokering deals and
soliciting new business opportunities, though he relies on his trusted associates to sign the
deals and to appear on all public documentation. Today’s action targets nine individuals that
have acted or purported to act for or on behalf of, directly or indirectly, Tesic:
• Goran Andric (Andric) is one of Tesic’s closest associates and has represented Tesic in various
international sales, including conducting contract negotiations on Tesic’s behalf while Tesic was
on the UN travel ban list and unable to travel. In working for Tesic, Andric was involved in
facilitating arms deals, including an occasion when Andric signed a contract on behalf of the
designated entity, Partizan Tech. In addition, OFAC designated Velcom Trade D.O.O. Beograd,
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which is based in Serbia, for being owned or controlled by, or for acting or purporting to act for
or on behalf of, directly or indirectly, Andric.
• Esad Kapidzic is the director and secretary of Cyprus-based Finrost Limited (Finrost), as well
as the director and representative of Serbia-based Falcon Strategic Solutions D.O.O. (Falcon
Strategic), two entities also designated for being owned or controlled by, or for acting or
purporting to act for or on behalf of, directly or indirectly, Tesic. Finrost received and moved
money on behalf of Tesic, and was used by Tesic for a weapons contract with a foreign
government in Africa. Additionally, Falcon Strategic was established by Tesic immediately
following his December 21, 2017 designation to avoid sanctions.
• Nebojsa Sarenac (Sarenac) is the managing director of both Technoglobal and Partizan Tech.
Sarenac is Tesic’s nephew and one of his closest associates.
Also designated today is Melvale Corporation D.O.O. Beograd (Melvale), which is based in
Serbia, for being owned or controlled by, or for acting or purporting to act for or on behalf of,
directly or indirectly, Sarenac, who is the owner and representative of Melvale.
• Zoran Petrovic is a managing director and principal of Partizan Tech, an entity designated in
December 2017. Petrovic has negotiated with foreign entities on Tesic’s behalf.
• Nikola Brkic is a principal and a legal representative of Partizan Tech.
• Milan Subotic (Subotic) is the owner and managing director, and a representative of Serbiabased Vectura Trans DOO (Vectura Trans), an entity that is being concurrently designated
today for being owned or controlled by, or for acting or purporting to act for or on behalf of,
directly or indirectly, Tesic. Tesic utilized Vectura Trans to receive an approved license for
exports, to complete arms deals, and to finalize weapons contracts with a foreign government.
Subotic was also listed as the point of contact for export permits related to Partizan Tech.
• Zelimir Petrovic is the owner, managing director, and representative of Serbia-based Araneks
DOO (Araneks), an entity that is being concurrently designated today for being owned or
controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Tesic.
Araneks was used by Tesic to finalize weapons contracts with a foreign government in Africa and
in dealings with another foreign government.
• Sreten Cvjetkovic is a 50 percent owner and representative of Falcon Strategic.
• Ljubo Maricic is the director of Technoglobal and a former representative of Partizan Arms,
predecessor to Partizan Tech.
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In addition to the six entities named above, OFAC is targeting three additional entities for being
owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly,
Tesic:
• The Cyprus-based Moonstorm Enterprises LTD, is an entity that is being concurrently
designated today for being owned or controlled by, or having acted or purported to act for or on
behalf of, directly or indirectly, Tesic.
• Tesic also utilized Cyprus-based Tardigrade Limited (Tardigrade) to conduct business in
third-party countries, particularly Arab and African countries. Tesic has also used his Serbian
companies to sign contracts with Tardigrade before selling the goods to a final buyer.
• Tesic established Hong Kong-based Business Diversity Limited in order to conduct business
with a European country. Tesic has used Business Diversity Limited in Euro denominated
contracts to evade U.S. sanctions.
VENEZUELA
Additionally, OFAC took action today against Gustavo Adolfo Vizcaino Gil (Vizcaino) and Juan
Carlos Dugarte Padron (Dugarte) pursuant to E.O. 13692, as amended, for being current or
former o icials of the Government of Venezuela.
In April 2016, Dugarte was named the Director General of the Government of Venezuela's
Administrative Service of Identification, Migration, and Immigration (Servicio Administrativo de
Identificación, Migración y Extranjería, or SAIME). While Dugarte was the Director General of
SAIME, he received kickbacks, and SAIME was publically implicated in corrupt dealings involving
the sale of passports.
In June 2018, Vizcaino was named the new Director General of SAIME, replacing Dugarte. Since
the fall of 2018, SAIME o icials and Vizcaino have been involved in corruption, charging passport
applicants thousands of dollars for passports and transferring those funds to Vizcaino's
personal foreign bank accounts. Additionally, under Vizcaino’s leadership, SAIME sold passports
to non-Venezuelan citizens for thousands of dollars per passport, and SAIME personnel were
members of illegitimate former Venezuelan President Nicolas Maduro’s armed groups known as
colectivos.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the individuals and entities
named above, and of any entities that are owned, directly or indirectly, 50 percent or more by
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them, individually, or with other 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. Unless
authorized by a general or specific license issued by OFAC or otherwise 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.
GLOBAL MAGNITSKY PROGRAM
Building upon the Global Magnitsky Human Rights Accountability Act, the President signed E.O.
13818 on December 20, 2017, in which the President found that the prevalence of human rights
abuse and corruption that originate, in whole or in substantial part, outside the United States,
had reached such scope and gravity that it threatens the stability of international political and
economic systems. Human rights abuse and corruption undermine the values that form an
essential foundation of stable, secure, and functioning societies; have devastating impacts on
individuals; weaken democratic institutions; degrade the rule of law; perpetuate violent
conflicts; facilitate the activities of dangerous persons; and undermine economic markets. The
United States seeks to impose tangible and significant consequences on those who commit
serious human rights abuse or engage in corruption, as well as to protect the financial system of
the United States from abuse by these same persons.
The U.S. Department of Homeland Security’s Human Rights Violators and War Crimes Center
assisted OFAC in identifying perpetrators of serious human rights abuse and corruption.
For more information on the individuals and entities designated today.
For more information on the statement and action taken by the Department of State in concert
with today’s sanctions.

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