OFAC Central African Republic Sanctions Regulations — Full Reissuance (31 CFR Part 553)

Mechanism

The Central African Republic sanctions program was established by President Obama's Executive Order 13667 (12 May 2014), which declared a national emergency with respect to the situation in the Central African Republic. The EO authorised the blocking of property of, and prohibitions on transactions with, persons determined to:

• Threaten the peace, security, or stability of the CAR;
• Obstruct the implementation of the peace process or the delivery of humanitarian

assistance;

• Be responsible for or complicit in human rights abuses in or in relation to CAR; or
• Have materially assisted, sponsored, or provided support to any of the above.

The original regulations (31 CFR Part 553) were published in abbreviated form on 7 July 2014 — a placeholder framework without full interpretive detail. The 2022 final rule replaces that placeholder with a complete regulatory text, adding:

• Definitions — clarifying the scope of "Government of the Central African

Republic," "person," "entity," and related terms for compliance purposes.

• General licenses — including GLs for personal remittances, humanitarian

assistance, NGO activities, and official government business.

• Interpretive guidance — on the "50-percent rule" for entities owned by

blocked persons, evasion provisions, and U-turn transaction prohibitions.

• Civil penalties framework — incorporating the standard OFAC penalty

structure (up to USD 1 million per violation or twice the transaction value).

Context: Wagner Group in CAR

Although the regulatory reissuance is procedural, it coincides with a period of intensified US enforcement focus on Russian-linked actors in CAR. The Wagner Group had embedded itself in CAR from 2018 onward, providing security forces to the government of President Faustin-Archange Touadéra in exchange for access to artisanal mining concessions (gold, diamonds, and timber extraction in the southern and eastern provinces). OFAC subsequently designated a cluster of Wagner-linked entities under EO 13667:

• Mining Industries SARLU and Logistique Economique Etrangere SARLU — Wagner

front companies enabling illicit mineral extraction and personnel logistics.

• Sewa Security Services — protection contractor for senior CAR government

officials.

• Kratol (designated January 2023) — material support provider for Wagner in CAR.

The 2022 regulatory reissuance provides the interpretive infrastructure for this enforcement campaign: defining "materially assisted" broadly enough to capture supply-chain and financial intermediaries servicing Wagner-linked entities.

Downstream implications

• US financial institutions must apply enhanced due diligence on transactions

with CAR-linked counterparties; the new definitions clarify the perimeter.

• General licenses for NGO and humanitarian activities reduce compliance friction

for aid organisations operating in CAR (one of the world's most acute displacement crises).

• The codified "50-percent rule" guidance locks in OFAC's standard aggregation

methodology for blocked entities — closing a compliance gap in the prior abbreviated regulations.

• Miners and commodity traders touching CAR-origin gold or diamonds must screen

against the SDN list; the expanded definitions increase the number of entities captured.

Open questions

• Whether the revised regulations will be further amended as OFAC continues

its 2023–24 Wagner designation campaign across the Sahel (Mali, Sudan, Libya).

• Whether the CAR government's continued reliance on Wagner/Africa Corps successors

post-Wagner-dissolution (mid-2023) triggers additional EO 13667 designations of state officials.