What OFAC sanctions did the Fénix mine receive and how were they lifted?

On 18 November 2022 the United States designated, under E.O. 13818 (Global Magnitsky), executives Dmitry Kudryakov (Russian) and Iryna Litviniuk (Belarusian) and the three Guatemalan companies controlled by Kudryakov, CGN,… Pronico and Mayaniquel, for 'multiple bribery schemes' involving politicians,… judges and officials (a primary OFAC action). On 17 January 2024 the sanctions on the three companies were lifted after an anti-corruption program with an independent monitor and the transfer of ownership to an entity incorporated in New York; the individuals had been designated separately. OFAC framed this as a response to changed conduct, not as an exoneration. The lesson: Fénix 'complied' with the consultation the Constitutional Court (CC) ordered and was still sanctioned eleven months later, procedural form is no shield against substance.