Sanjay Keshavji Vaya (Sanjay) is considered Pattni’s “right hand man” as relates to his Zimbabwe-based activities, and his son Raj Vaya Sanjay (Raj) has been identified as supporting Pattni by providing him gold and acting as a director on the Pattni-controlled Skorus Investments (PVT) LTD. Another director of Skorus Investments Limited is David Paul Crosby (Crosby), who also provides gold for Pattni and acted as a courier in the network. Crosby controls several companies based in Kyrgyzstan, including Sakhara Petroleum OSOO, Mirdk Fyuels OSOO, Royal Sona OSOO, and Suprim Ef Iks OSOO. Finally, Dmytro Abakumov (Abakumov) has been a courier for Pattni and was at one time his personal trader. Sun Multinational, Marwa Investments Limited, Fiza Gold and Bullion Trading L.L.C, Golden Luxury Jewellery Trading L.L.C, Ruhmeer Diamonds DMCC, Precious Bullion DMCC, Star Travel & Tourism L.L.C, Rubini Investment Group Limited, Samaria Holdings Limited, Suzan General Trading JLT, Manurama Limited, Suzan General Trading (PVT) LTD, and Skorus Investments (PVT) LTD are being designated pursuant to E.O. 13818 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Pattni.
On December 23, 2016, the President signed the Global Magnitsky Human Rights Accountability Act (Pub. L. 114-328, Title XII, Subtitle F) (the “Act”) into law. The Act authorized the President to impose targeted sanctions on any foreign person the President determines is, among other things, responsible for extrajudicial killings, torture, or other gross violations of internationally recognized human rights, or a government official, or a senior associate of such an official, responsible for, or complicit in, ordering, controlling, or otherwise directing, acts of significant corruption.
On December 20, 2017, the President, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701-1706) (IEEPA), issued Executive Order 13818 (82 FR 60839, December 26, 2017) (E.O. 13818), effective at 12:01 a.m. eastern standard time on December 21, 2017.
In E.O. 13818, the President determined that serious human rights abuse and corruption around the world constitute an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States and declared a national emergency to deal with that threat.
OFAC is issuing the Global Magnitsky Sanctions Regulations, 31 CFR part 583 (the “Regulations”), to implement the Act and E.O. 13818, pursuant to authorities delegated to the Secretary of the Treasury in E.O. 13818. A copy of E.O. 13818 appears in appendix A to this part.
