On November 12, President Barack Obama issued an executive order terminating the U.S. sanctions program against certain transactions in Liberia. Since 2004, the Office of Foreign Assets Control (OFAC) administered targeted sanctions against the former Liberian regime of Charles Taylor. These sanctions prohibited transactions with individuals and entities who materially assisted Taylor’s regime, including senior officials in the regime as well as immediate family members. These individuals and entities were designated by OFAC and placed on OFAC’s Specially Designated Nationals and Blocked Persons (SDN) list, therefore blocking the property and interests in property of those persons, including entities 50 percent or more owned by those persons, from transactions with U.S. persons or otherwise involving a U.S. nexus. Concurrent with the executive order, OFAC has now removed the SDN designations for these individuals and entities.
Taylor, Liberia’s president from 1997 to 2003, was convicted of 11 counts of war crimes in 2012 by the Special Court for Sierra Leone and sentenced to 50 years in prison. The Liberian sanctions program was designed to limit Taylor’s ability to destabilize western Africa, conceal and move Liberian funds and property, and deplete Liberian resources. The executive order cites the following reasons for Taylor’s diminished ability to influence Liberia: the development of political and economic institutions in Liberia after the Taylor regime, 2005 and 2011 free elections of current President Ellen Johnson Sirleaf, and Taylor’s conviction upheld on appeal.
The Liberian sanctions program terminated effective Nov.12, 2015, and a number of individuals and entities were removed from the SDN list. As a result, property of those delisted SDNs previously blocked can now be released without the need for a general or specific license from OFAC. Any enforcement action pending or penalty assessed under the Liberian sanctions program prior to Nov.12, however, remains unaffected by the executive order.