OFAC’s enlightenment, Demerara Bank, GBTI enforcement

Aug 18, 2025 Features / Columnists, The GHK Lall Column

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Kaieteur News – The United States Department of the Treasury, Office of Foreign Assets Control (OFAC) has cut through the murk about its sanctions, spoken in unambiguous terms, and provided proper enlightenment. Those should be extremely helpful for Guyanese of all intelligence levels and political colors.

Though, Guyanese murkiness re the implications and applications of OFAC’s sanctions may have been self-imposed, that condition should now be abandoned, since the issue of whose is impacted is rendered moot today. Now that the good officers of the Demerara Bank know, what should they do? They should move with haste to reinstate those 20 or so accounts, and write letters of apology to the affected Guyanese, their longstanding, unsanctioned customers. Although an apology to the public may make Demerara Bank look good, as truly balanced and conservative entity, a reputable outfit, I do not think that such is not compulsory for the public. It has enough self-inflicted damage to undo. So, let us all be understanding, forgiving, and readying to move along.

Demerara Bank, and its learned allies, peddled a lot of dogmeat as prime cuts relative to the OFAC sanctions. Risk was held out as a reasonable concern, what any entity that puts a premium on self-protection, when the people of WIN-unsanctioned and law-abiding Guyanese, customers in good standing-were sent packing, essentially dumped in a no man’s land, with sharks and wolves for company. This is the Guyana that is abhorred, because I find it so viscerally demeaning, so mentally calculating. But the banks were having none of those qualms, with the GBTI, going even further and terminating Mr. Corwyn Austin for being on the elections’ list of a US-sanctioned individual. If for that, then what is left, what is constitutionally free, what is lawful, for Guyanese to do?

When the bank’s actions, and its support system rallied to its side, two thoughts surfaced. First, did the bank’s legal and compliance department seek guidance from the people of OFAC? And, second, now that its people had been sucker punched, and a hole dug in its operations, would WIN take that sitting down? For, if the Mohameds had the kind of quality US counsel suspected, then they had to earn their money by reaching to OFAC for guidance. From experience, this is kind of interpretative guidance that was sought as a matter of routine from the New York Stock Exchange, and the Securities and Exchange Commission, among others. Before certain far-reaching actions were enforced, that first step had to be followed. It was mandatory.

Apparently, counsel for the Mohameds did so. Because in two simple sentences, OFAC delivered what is commonsense and also Solomonic: “implications of transacting with a political party led by an individual sanctioned by OFAC or with members of such a political party would depend on whether the sanctioned individual is involved in the transaction (italics mine).” And, in a further bit of handholding, “U.S financial institutions would not violate sanctions for maintaining the account of or processing a transaction involving a non-sanctioned organization or non-sanctioned members of that party solely because another member is sanctioned (again, italics added for emphasis).” If those words are good enough, have considerable weight, for U.S. financial institutions, then I think that Guyanese ones would be in extremely good company.

Far be it from me to tell Demerara Bank, and also the GBTI (or any other financial entity in Guyana) what their course of action should be in the interests of managerial principles and organizational reputations. But I would be remiss, given the circumstances, if I didn’t strongly and respectfully recommend to Demerara Bank, GBTI, et al that they reverse their earlier decisions to close bank accounts of Guyanese associated with the sanctioned Mohamed(s). Reverse and restore. Guyanese, be they of the PPP Government leadership, or private sector commercial enterprises, should have learned a lesson, a hard one, while whole world watched. The simple lesson is that Americans should not be feared to such an extent that their every word and deed are followed slavishly. Americans with class don’t like that, look poorly at such native practitioners of what is nauseatingly obsequious. Demerara Bank and GBTI practiced both, and with their heels dug in stubbornly.

In leaving this sorry affair behind, I refrain from inserting today any idea revolving around political favors thought to be done by the actions of the local banks. Or any political instructions that may have come through the underground channels now part of the information highway in this country. Reinstate the 20 bank accounts is my caution to Demerara Bank. And reinstate Mr. Corwyn Austin is the advice extended to GBTI. Both pieces of consultation are free of charge. Another hand: all these troubling, degrading, exercises in domestic citizenship, may they be the last. May there be truly free and fair elections.

(The views expressed in this article are those of the author and do not necessarily reflect the opinions of this newspaper.)

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• Demerara Bank, GBTI, GHK Lall, OFAC’s, sanctions

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