Sanctions Designation Analysis for February 26, 2026 Nicaragua Designations under E.O. 13581
On February 26, 2026, OFAC designated five Nicaraguan government officials under Executive Order 13851 (as amended by E.O. 14088) for their roles in enabling the Murillo-Ortega dictatorship’s repression. This action represents a rare human rights-based designation by the second Trump administration, whose sanctions priorities have focused overwhelmingly on Iran, counter-narcotics, and counter-terrorism.
| Official | Position | Basis for Designation |
|---|---|---|
| Denis Membreno Rivas | Director, Financial Analysis Unit (UAF) | Weaponizing AML/CFT systems against political opponents |
| Aldo Martin Saenz Ulloa | Deputy Director, UAF | Co-led UAF since 2012; same weaponization of AML/CFT |
| Johana Vanessa Flores Jimenez | Minister of Labor | Labor rights abuses and unfair conditions of competition |
| Celia Margarita Reyes Ochoa | Deputy Dir. General, TELCOR | Regime surveillance and communications control apparatus |
| Leonel Jose Gutierrez Lopez | Head, DICIM (Military Intelligence) | Internal/external surveillance and repression coordination |
Legal Basis: All five designated as “officials of the Government of Nicaragua…at any time on or after January 10, 2007” — the broadest available criterion under E.O. 13851. Standard blocking language applies; the 50% Rule extends to owned entities.
Designations (2025)
Designations
Crime Targets
Designees
Source: CNAS “Sanctions by the Numbers: 2025 Year in Review” (January 2026)
Commonalities with Administration Policy
Distinctions from Administration Policy
Human Rights Deprioritization: In April 2025, the Trump administration delisted a Biden-era Global Magnitsky designee (a Hungarian official). The administration’s only Global Magnitsky designation — Brazilian Justice Alexandre de Moraes (July 2025) — was itself delisted in December 2025. The West Bank sanctions program was terminated on Inauguration Day.
