The White House has issued an Executive Order establishing a new sanctions regime targeting individuals deemed to be contributing to the severe instability in the Central African Republic (CAR). The new sanctions come a month after the U.S. Government’s implementation of a UN arms embargo issued earlier this year, which prohibits exports to the CAR of defense articles or defense services subject to the International Traffic in Arms Regulations (ITAR) in nearly all circumstances.

The CAR continues to suffer from widespread civil unrest, and there are growing reports of human rights violations, including apparent massacres of Muslim civilians committed by Anti-Balaka militias, stemming from a 2012 rebel uprising. In response to the violence, on May 13, 2014, the President issued an Executive Order establishing CAR-related sanctions. The new measures impose targeted sanctions on specific individuals, including the blocking (or freezing) of assets and visa bans for entry into the United States. The sanctions effectively prohibit U.S. persons from engaging in any transactions with the following five individuals:

  •  Noureddine Adam (General and Former CAR Minister of Public Security)
  •  Francois Bozize (Former CAR President)
  •  Michel Djotodia (Former CAR Transitional President)
  •  Abdoulaye Miskine (Leader of the Democratic Front of the CAR)
  •  Levi Yakite (Anti-Balaka Political Coordinator)

In addition to the five newly-designated individuals listed above, the Executive Order also grants the Secretary of the Treasury authority to impose sanctions on additional individuals or entities deemed to contribute to instability in the CAR. The U.S. Government may therefore expand the list of sanctioned individuals in the coming months.

Given the deteriorating situation in the CAR, U.S. persons should exercise caution in dealings, direct and indirect, with all entities and individuals in or related to the CAR. Importantly, U.S. persons should conduct “party screening” of all entities in a proposed transaction against, at a minimum, the U.S. Department of the Treasury’s Specially Designated Nationals (SDN) List.