Dubai, United Arab Emirates;
Calle Muntaner 325, Planta 6, 4, Barcelona, 08021, Spain;
Calle Los Geranios, Villa Indelo N 244, San Pedro De Alcantara, Marbella, Spain;
Urbanizacion Torre Bermeja, N 1501, Estepona, Spain
Irish national Christopher Vincent Kinahan Senior (Christopher Sr.), currently based in Dubai, was designated for acting or purporting to act for or on behalf of, directly or indirectly, the KOCG. Demonstrative of a long history of criminality, Christopher Sr. has served prison sentences in Ireland, the Netherlands, and Belgium, including: six years for dealing heroin, two-and-a-half years for possession of cocaine, and four years for money laundering. During this time he was building a list of contacts that grew to what became known as the KOCG. Christopher Sr.’s sons, Daniel Kinahan and Christopher Jr., now manage his drug trafficking operations while Christopher Sr. oversees the property portions of the enterprise. For example, Christopher Sr. has registered a number of companies under aliases or using abbreviations of his name. Christopher Sr. has been known to have used false identity documents.
Transnational Criminal Organizations Sanctions Regulations, 31 C.F.R. part 590;
Executive Order 13581 of July 24, 2011 Blocking Property of Transnational Criminal Organizations
Regime
OFAC-horizontal
Target State
Criminal organizations
Measures
Blocking Property
Official Information
On January 12, 2012, OFAC issued the Transnational Criminal Organizations Sanctions Regulations, 31 CFR part 590 (77 FR 1864, January 12, 2012) (the “Regulations”), to implement Executive Order (E.O.) 13581 of July 24, 2011, “Blocking Property of Transnational Criminal Organizations” (76 FR 44757, July 27, 2011), pursuant to authorities delegated to the Secretary of the Treasury in E.O. 13581. The Regulations were initially issued in abbreviated form for the purpose of providing immediate guidance to the public. OFAC amended the Regulations on July 23, 2019 (84 FR 35307, July 23, 2019) to implement E.O. 13863 of March 15, 2019, “Taking Additional Steps to Address the National Emergency With Respect to Significant Transnational Criminal Organizations” (84 FR 10255, March 19, 2019), which amended E.O. 13581. OFAC is amending and reissuing the Regulations as a more comprehensive set of regulations that includes additional interpretive guidance and definitions, general licenses, and other regulatory provisions that will provide further guidance to the public. Due to the number of regulatory sections being updated or added, OFAC is reissuing the Regulations in their entirety.
E.O. 13581 On July 24, 2011, the President, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), issued E.O. 13581. In E.O. 13581, the President found that the activities of significant transnational criminal organizations, such as those listed in the Annex to E.O. 13581, have reached such scope and gravity that they threaten the stability of international political and economic systems. The President further found that such organizations are becoming increasingly sophisticated and dangerous to the United States; they are increasingly entrenched in the operations of foreign governments and the international financial system, thereby weakening democratic institutions, degrading the rule of law, and undermining economic markets. The President stated these organizations facilitate and aggravate violent civil conflicts and increasingly facilitate the activities of other dangerous persons. The President determined that the activities of significant transnational criminal organizations 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.
