OFAC sanctions on the Fénix mine and their lifting

Dossier: Social license and prior consultation23-licencia-social.md
Domain: Social license and prior consultationlicencia-social
Room: Law/ley
Audited: Audited

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, confirmed in the audit). 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.

The research is written in English; quoted figures, source names and the titles of legal instruments stay in the language their source published them in.

Figures

OFAC designation (CGN, Pronico, Mayaniquel + 2 executives)OFAC: 18 Nov 20222022
Delisting of the three companiesLatam Reports / Prensa Libre: 17 Jan 20242024

Sources

OFAC, Recent Actions 18-nov-2022ofac.treasury.govconsulted Aug 19, 2026
Herbert Smith Freehills, OFAC targets corruption in Guatemala mining sectorhsfnotes.comconsulted Aug 19, 2026
Latam Reports, OFAC lifts sanctions on Mayaniquel, CGN and Pronicolatamreports.comconsulted Aug 19, 2026
Prensa Libre, OFAC levanta sanciones a Mayaniquel, CGN y Pronicoprensalibre.comconsulted Aug 19, 2026

Organizations named in the answer

PronicoA company in the Fénix complex (CGN-Pronico, formerly Solway) at El Estor; designated by OFAC on 18 November 2022 and delisted on 17 January 2024.Company case
MayaniquelThe third Guatemalan company controlled by Dmitry Kudryakov to be designated by OFAC (18 November 2022) over bribery schemes; delisted on 17 January 2024.Company case

Directory of organizations

Related records

This layer is research: read from public sources by the archive's own team, every claim cited with the date it was consulted, and audited where it is marked so. It has not entered the verified store — no figure here was fetched back from its source or stamped with a retrieval time — so it wears no red provenance numeral and never mixes with the verified figures.