• International Lawyers Project

UK Global Anti-Corruption Sanctions Regime Workshop for Latin American Civil Society Lawyers

Updated: Apr 20


What are targeted sanctions?


In contrast to traditional economic sanctions, targeted sanctions like the ones imposed under the UK Global Anti-Corruption Sanctions Regime or the US Global Magnitsky Act focus on the corrupt actors themselves, rather than an entire country. This avoids the collateral damage of traditional economic sanctions which can end up harming the victims of corruption more than its perpetrators. When an individual, a corporation or an organisation is sanctioned - ‘designated’ - their assets are frozen. Individuals are banned from travelling to the country that issued the sanction. Anti-corruption sanctions can often help to disable high-level corrupt networks in authoritarian regimes where the criminal justice system has otherwise failed due to the complicity of a case or the jurisdictions involved.


 


2021 Designations by the UK and US government for corruption in Latin America


Targeted sanctions have the most impact when implemented by multiple countries; they remove avenues for kleptocrats to spend, hide or launder bribes or stolen funds. It also sends a strong international message to corrupt actors that they cannot act with impunity. Below are examples of UK and US designations in Latin America and the types of serious corruption kleptocrats are being held accountable.

Country

Names

Description

Sanctions Regime

Guatemala

  • Felipe Alejos Lorenzana

  • Gustavo Adolfo Alejos Cambara

Felipe Alejos Lorenzana, the Vice President of the Congress, and Gustavo Adolfo Alejos Cambara, former Chief of Staff for the Alvaro Colom presidential administration from 2008–2012, were designated by the USA and the UK. While in pre-trial detention for corruption, Cambara tried to influence the judicial selection process by reportedly facilitating payments to congressional representatives and judges in coordination with Lorenzana, in order to shield themselves from prosecution.


​UK Global Anti-Corruption Sanctions Regime


US Global Magnitsky Act


From left to right: Felipe Alejos Lorenzana, as Vice President of the Congress of Guatemala

Luis Almagro, OAS Secretary General, Washington D.C., 2016



Country

Names

Description

Sanctions Regime

Columbia/Venezuela (Dual Nationality)

  • Alex Saab

  • Alvaro Enrique Pulido Vargas*





*Not designated under US Global Magnitsky Act

Alex Saab and Alvaro Enrique Pulido Vargas were designated in the UK and USA for reportedly inflating public procurement contracts intended to supply poor Venezuelan families with affordable food and housing. Saab was extradited to the US in October 2021 and charged with laundering $350 million out of Venezuela into the US and other countries.



​​​UK Global Anti-Corruption Sanctions Regime

US Global Magnitsky Act

Honduras

Oscar Nájera

​Oscar Nájera, a Congressman, was designated under the UK Anti-Corruption Sanctions Regime for his involvement in serious corruption and using his position to facilitate bribes that supported a major drug trafficking organisation, ‘Los Cachiros’, one of Honduras' largest drug trafficking groups, with a net worth close to $1 billion. The organization became a major player in the movement of cocaine between Colombian and Mexican organizations.

UK Global Anti-Corruption Sanctions Regime

Mexico

  • ​Roberto Sandoval Castaneda

  • Ana Lilia Lopez Torres

  • Pablo Roberto Sandoval Lopez

  • Lidy Alejandra Sandoval Lopez



Roberto Sandoval Castaneda is a Mexican politician alleged to have misappropriated state assets and received bribes from numerous drug cartels in exchange for information and protection. Ana, Lidy and Pablo, Sandoval’s wife and children, were all designated for aiding Sandoval.

US Global Magnitsky Act


 


Training Anti-Corruption Activists on UK Sanctions Tools


Transparency International (TI), the world’s leading anti-corruption NGO, requested ILP’s assistance in organising a virtual workshop to provide an overview and training on the UK Global Anti-Corruption Sanctions Regime. On the 4th November 2021, Oliver Windridge, an international sanctions lawyer, conducted the workshop for 31 in-house anti-corruption lawyers. These lawyers represented 13 TI NGO chapters located across Latin and Central America. The workshop was also attended by in-country diplomats from the UK’s Foreign, Commonwealth & Development Office (FCDO) working in the region.


The ILP-TI workshop aimed to address the issue of extensive grand corruption in Latin America. The region is often plagued by an inability to hold corrupt officials and elected leaders accountable for bribery, tax evasion and related crimes. Accordingly, the Sanctions Regime offers hope to civil society in these countries that there are new enforcement tools that they can use.


Trainer and sanctions lawyer Oliver Windridge.


During the workshop, Oliver provided:

  • an introduction and overview of the Sanctions Regime;

  • training on how to use the Sanctions Regime to increase accountability for corruption between Latin America and the UK;

  • knowledge to equip the participants on how to make strong submissions to the UK government for sanctions;

  • a description of cases where certain Latin American individuals have been designated under the Sanctions Regime already;

  • advice on how submissions can be made confidentially or in a manner which helps to protect anti-corruption activists, their sources and whistle-blowers.

Oliver also took part in a lively 30 minute Q&A session using examples of his experience of making submissions for corruption


For more information on the workshop, please find the full recording and powerpoint slides of the workshop below. Also found below is a briefing note with FAQs on the UK Anti-Corruption Sanctions Regime produced for civil society activists.


 

For more information on the workshop, please find the full recording and powerpoint slides of the workshop here.


For a briefing note with FAQs on the UK Anti-Corruption Sanctions Regime produced for civil society activists please click here.