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On March 4, 2024, the United States terminated its long-standing list-based sanctions program targeting certain members of the Government of Zimbabwe and other persons for undermining Zimbabwe’s democratic processes or institutions. As a result, blocking sanctions imposed on persons and property blocked solely under the Zimbabwe program are no longer in effect, and OFAC will remove the Zimbabwe Sanctions Regulations (31 CFR 541) from the Code of Federal Regulations.

Upon issuance of the Executive Order of March 4 terminating the national emergency upon which the sanctions were based and revoking the Executive Orders that authorized the Zimbabwe sanctions (EO 13288 (2003), EO 13391 (2005) and EO 13469 (2008)), the Department of Treasury’s Office of Foreign Assets Control (OFAC) updated the Specially Designated Nationals and Blocked Persons List (SDN List) to remove all the SDNs previously designated under the Zimbabwe program, including deceased former president Robert Mugabe (133 removals in total).

However, the U.S. government warned that it continues to be “deeply concerned about democratic backsliding, human rights abuses, and government corruption in Zimbabwe,” and what it characterized as “President Mnangagwa’s criminal network of government officials and businesspeople who are most responsible for corruption or human rights abuse.” As a practical expression of that concern, the Treasury immediately redesignated 12 SDNs formerly designated under the Zimbabwe sanctions (including President Emmerson Mnangagwa) and added two new Zimbabwe-related SDNs (including First Lady Auxilia Mnangagwa) for involvement in corruption or serious human rights, all under the authority of the Global Magnitsky sanctions program.

The new and redesignated SDNs in Zimbabwe, and their roles and relationships according to OFAC, are listed below. Importantly, OFAC’s explanations of the designations identify the following non-designated government organizations as having engaged in serious human rights abuses: Zimbabwe’s security forces, Joint Operation Command, Central Intelligence Organization (CIO), and Zimbabwe Republic Police (ZRP). Against the backdrop of corruption and human rights abuses highlighted by today’s actions, companies should continue to carefully review proposed transactions involving government entities and officials in Zimbabwe.

1. [Redesignated] President Emmerson Mnangagwa
2. [New] Current First Lady Auxilia Mnangagwa
3. [New] Retired Brigadier General Asher Walter Tapfumaneyi, Deputy Director General of Zimbabwe’s Central Intelligence Organization (CIO)
4. [Redesignated] Kudakwashe Regimond Tagwirei (businessman, close ally of Mnangagwa with longstanding association to ruling party Zimbabwe African National Union-Patriotic Front (ZANU-PF)).
5. [Redesignated] Sandra Mpunga (Tagwirei’s wife);
6. [Redesignated] Sakunda Holdings (a business owned by Tagwirei and Mpunga)
7. [Redesignated] Fossil Agro (a subsidiary of Sakunda Holdings
8. [Redesignated] Obey Chimuka (Fossil Agro director and longtime Tagwirei business partner)
9. [Redesignated] Fossil Contracting (owned by Chimuka)
10. [Redesignated] First Vice-President Constantino Chiwenga, who has a leadership role with respect to Zimbabwe’s security forces
11. [Redesignated] Defense Minister Oppah Muchinguri
12. [Redesignated] Godwin Matanga, Commissioner-General of the Zimbabwe Republic Police (ZRP)
13. [Redesignated] Stephen Mutamba, Deputy Commissioner-General of the ZRP
14. [Redesignated] Owen Ncube, former Minister of State Security (2018-2022), now Minister of State for Midlands Provincial Affairs

For more information on the topics covered in this advisory or any other aspect of U.S. export controls or economic sanctions, contact Partner Tahlia Townsend, co-chair of Wiggin and Dana’s International Trade Compliance Practice Group.