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12/1/2023

Treasury Sanctions Former Guatemalan Government Official for Engaging in Public Corruption | U.S. Department of th…

Treasury Sanctions Former Guatemalan Government Official for
Engaging in Public Corruption
December 1, 2023

WASHINGTON — Today, the Department of the Treasuryʼs O ice of Foreign Assets Control
(OFAC) sanctioned Luis Miguel Martinez Morales (Martinez) for his role in corruption in
Guatemala wherein he engaged in widespread bribery schemes, including schemes related to
government contracts. Martinez is being designated 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 around the world.
“Todayʼs action underscores the corrosive impact of corruption on the publicʼs trust in
government institutions. Martinez sought to leverage his privileged position for personal
benefit at the expense of the Guatemalan people,” said Treasuryʼs Under Secretary for
Terrorism and Financial Intelligence Brian E. Nelson. “The U.S. government will continue to
hold accountable individuals whose corrupt schemes undermine democracy and do harm to
populations around the world.”
Todayʼs action builds on the Administrationʼs e orts to address corruption as a root cause of
irregular migration through the northern Central America region. Corrupt and anti-democratic
acts, including those that threaten the integrity of an orderly transition of power in
Guatemala, undermine Guatemalaʼs democratic institutions and threaten the stability of
Guatemala and the region as a whole. The Guatemalan people have spoken and their voices
must be respected.
Since 2021, the U.S. government has sanctioned 11 individuals and entities in Guatemala for
their roles in corruption. The Department of State also has used a range of visa restriction
tools, to promote accountability for corrupt and undemocratic actors in Guatemala. These
actions demonstrate the U.S. governmentʼs continued commitment to stand by the
Guatemalan people.

LUIS MIGUEL MART INEZ MORALES

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Treasury Sanctions Former Guatemalan Government Official for Engaging in Public Corruption | U.S. Department of th…

Martinez is the former head of the now-defunct Centro de Gobierno, a powerful quasicabinet level agency created by Guatemalan President Alejandro Giammattei (Giammattei) at
the start of his administration. President Giammattei was forced to shut down the Centro de
Gobierno in December 2020 following backlash to Martinezʼ rising power in the government.
During his time as the head of Centro de Gobierno, Martinez was considered one of the most
powerful unelected o icials in the government. While he does not currently hold a government
position, Martinez remains one of the most influential individuals in the Giammattei
administration.
Martinez has influenced the government contracts process to benefit himself and close
associates. Martinez colluded with other Guatemalan government o icials to illegally award
contracts to favored bidders outside of Guatecompras, the Guatemalan governmentʼs formal
procurement system. Martinez and his conspirators used antiquated procurement law to
forego the bidding process and secure government contracts for companies in which he has a
financial interest.
In 2021, Martinez solicited large kickbacks to facilitate the purchase of the Russian Sputnik V
vaccines by the Government of Guatemala. Guatemalaʼs special anti-corruption agency
investigated Martinez for his role in a controversial payment tied to the purchase of 16
million doses of Russian Sputnik V COVID-19 vaccines by the Guatemalan government.
Martinez is being designated pursuant to E.O. 13818 for being a foreign person who is a
current or former government o icial, or person acting for or on behalf of such an o icial, who
is responsible for or complicit in, or who 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.

SANCT IONS IMPLICAT IONS
As a result of todayʼs action, all property and interests in property of the person described
above 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 percent or more by one or more blocked persons are also
blocked. Unless authorized by a general or specific license issued by OFAC, or otherwise
exempt, OFACʼs 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
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Treasury Sanctions Former Guatemalan Government Official for Engaging in Public Corruption | U.S. Department of th…

or otherwise blocked persons. 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.
The power and integrity of OFAC sanctions derive not only from OFACʼs ability to designate
and add persons to the SDN List, but also from its willingness to remove persons from the
Specially Designated Nationals and Blocked Persons (SDN List) consistent with the law. The
ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior.
For information concerning the process for seeking removal from an OFAC list, including the
SDN List, please refer to OFACʼs Frequently Asked Question 897 here. For detailed information
on the process to submit a request for removal from an OFAC sanctions list, please click here.

GLOB AL MAGNITSKY
Building upon the Global Magnitsky Human Rights Accountability Act, E.O. 13818 was issued
on December 20, 2017, in recognition that the prevalence of human rights abuse and
corruption that have their source, in whole or in substantial part, outside the United States,
had reached such scope and gravity as to threaten 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.
Click here for more information on the individuals designated today.
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