GUYANA | US Sanctions Nazar, Azruddin Mohamed, PS Mae Thomas for Corruption

WASHINGTON, DC, Treasury Department -   June 11, 2024 Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned members of one of Guyana’s wealthiest families, Nazar Mohamed and his son, Azruddin Mohamed, their company, Mohamed’s Enterprise, and a Guyanese government official, Mae Thomas, for their roles in alleged public corruption in Guyana.

Additionally, OFAC designated two other entities, Hadi’s World and Team Mohamed’s Racing Team, for being owned or controlled by Mohamed’s Enterprise and Azruddin, respectively.

These individuals and entities are sanctioned 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.

“Today’s action underscores our commitment to holding accountable those who seek to exploit Guyana’s underdeveloped gold sector for personal gain,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson.

“Treasury, in close coordination with our partners in U.S. law enforcement, will continue to take action to safeguard the U.S. financial system from abuse by corrupt actors.”

These actions were conducted in coordination with Homeland Security Investigations New York Organized Crime Drug Enforcement Task Force (OCDETF) Strike Force, Diplomatic Security Service, Customs and Border Protection (CBP) Office of Intelligence – New York Operations, and the Federal Bureau of Investigation’s Miami Field Office, with assistance from HSI Miami, CBP Miami and New York Field Offices, New York City Police Department Intelligence Bureau, and the Drug Enforcement Administration.

THE MOHAMED’S ABUSE OF GUYANA’S GOLD INDUSTRY

Gold is one of Guyana’s main exports, but it remains a highly fractured industry with small-scale gold mining operations in Guyana occupying a majority share of the country’s gold production.

These small, family-owned businesses have informal relationships with larger purchasers and traders like Mohamed’s Enterprise. Once mined, Guyanese gold is sold and traded throughout international markets, including the United States, Canada, the United Arab Emirates, and the European Union.

Nazar Mohamed founded Mohamed’s Enterprise in Guyana before expanding to the United States as a moneychanger and transitioned into gold trading, growing Mohamed’s Enterprise into one of Guyana’s largest gold exporters.

In time, Azruddin Mohamed ultimately took over Mohamed’s Enterprise, which also now does business as “Confidential Cambio.”

Azruddin and Mohamed’s Enterprise allegedly evaded Guyana’s tax on gold exports and defrauded the Guyanese government of tax revenues by under-­declaring their gold exports to Guyanese authorities.

Between 2019 and 2023, Mohamed’s Enterprise allegedlly omitted more than 10 thousand kilograms of gold from import and export declarations and avoided paying more than $50 million in duty taxes to the Government of Guyana.

Mohamed’s Enterprise has allegedly bribed customs officials to falsify import and export documents, as well as to facilitate illicit gold shipments. Mohamed’s Enterprise had allegedly paid bribes to Guyanese government officials to ensure the undisrupted flow of inbound and outbound personnel that move currency and other items on behalf of Azruddin and Mohamed’s Enterprise.

In addition, Azruddin is the principal and owner of Team Mohamed’s Racing Team, a drag racing organization in Guyana. Hadi’s World is a Guyana-based subsidiary of Mohamed’s Enterprise.

MOHAMED’S CORRUPTION ENABLED BY GUYANESE OFFICIALS

To conceal their alleged illegal activity and operate with impunity, Azruddin and Mohamed’s Enterprise have engaged in extensive bribery schemes involving government officials in Guyana.

This includes allegedly providing direct and recurring bribery payments to Guyanese government officials to ensure favorable treatment in criminal or civil matters that would otherwise suggest their involvement in illegal criminal activity.

In return, corrupt officials receive cash and gifts for incidents that are overlooked. Additionally, Mohamed’s Enterprise has allegedly paid bribes to corrupt Guyanese government officials to facilitate the award of government contracts.

One such official, Mae Thomas, was the Permanent Secretary to Guyana’s Minister of Home Affairs from October 2020 through August 2023, and is the current Permanent Secretary of the Ministry of Labour. A corrupt Permanent Secretary could manipulate procurement processes to suit their preferred bidder by providing inside information at the early stages of evaluation.

Access to a Permanent Secretary of any Ministry could afford contractors insight into upcoming projects and bid values. Permanent Secretaries can act as the legal authority to sign contracts on behalf of their ministry.

While Permanent Secretary to Guyana’s Minister of Home Affairs, Thomas allegedly used her position to offer benefits to Mohamed’s Enterprise and Azruddin, among others, in exchange for cash payments and high-value gifts.

Thomas allegedly misused her position to influence the award of official contract bids and the approval processes for weapons permits and passports on behalf of Mohamed’s Enterprise.

OFAC is designating Azruddin and Mohamed’s Enterprise for being persons who have allegedly materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, 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, that is conducted by a foreign person.

OFAC is designating Nazar for allegedly being a foreign person who is or has been a leader or official of Mohamed’s Enterprise, an entity whose property and interests in property are blocked pursuant to E.O. 13818, as a result of activities related to Nazar’s tenure.

OFAC is designating Team Mohamed’s Racing Team for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Azruddin.

OFAC is designating Hadi’s World for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Mohamed’s Enterprise.

OFAC is designating Thomas for being a foreign person who is a current or former government official, or a person acting for or on behalf of such an official, who is allegedly 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.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of the designated persons 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 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.

In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entities and individuals may expose themselves to sanctions or be subject to an enforcement action.

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 OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the 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 OFAC’s Frequently Asked Question 897. For detailed information on the process to submit a request for removal from an OFAC sanctions list.

GLOBAL 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.

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