subsidiaries are both listed, causing some difficulty. Controversial Chinese businessperson Sam Pa, for example, is listed more than a dozen times under each of his aliases. However, there appears to be 53 entities presently on the SDN list. Of these, 21 are farms held by companies whose beneficial owners are some of the listed individuals. 17 of the remaining 32 companies are linked to John Bredencamp and were probably listed on account of the Zimbabwean entrepreneur’s involvement in controversial and government/military linked mining deals in the Democratic Republic of Congo and arms dealing. Gécamines’s DRC based Kababankola Mining Company and Operation Sovereign Legitimacy (Osleg) Pvt Ltd are also part of the last 15 listed, for similar reasons. Four of these 15 are companies where the beneficial owner is a SDN – Comoil (Pvt) Ltd (Saviour Kasukuwere); Famba Safaris (Webster Shamu) and Divine Homes (Pvt) Ltd (Edmore Veterai) and SinoZim, believed to be a joint venture between Sam Pa and the C.I.O. and involved in exploiting Marange diamonds.25 Similarly, three companies are listed probably on account of human rights abuses and corrupt practices linked to the Zimbabwe military’s involvement in the exploitation of Marange diamonds – Block Wood Mining (a.k.a. Marange Resources) Condurango Investments Pvt Ltd a.ka. Mbada Diamond Mining and Zimbabwe Defence Industries (Pvt) Ltd. The last is listed by all countries with designated Zimbabwean entities on account of the arms embargo. Two ZANU PF party Companies are listed – M & S Syndicate (Pvt) Ltd and ZIDCO Holdings (Pvt) Ltd. Companies in the ZIDCO stable are FBC Bank; Jongwe Printing & Publishing Company; Treger Holdings; Catercraft; Zidlee Enterprises; Ottawa (a property management firm); Oryx Diamonds; Southern Africa Reinsurance (Sare) and NDH Holdings (Pvt) Ltd. These companies only fall under the OFAC regulations if 50% or more of the beneficial ownership is that of ZIDCO.26 Jongwe Printing is listed separately as a designated entity but this is unnecessary if ZIDCO has a 50% or more holding in the company. The last three entities are the moribund (and plundered27) Zimbabwe Iron and Steel Company (ZISCO) Zimbabwe Mining Development Corporation (ZMDC) Minerals Marketing Corporation of Zimbabwe (MMCZ). The inclusion of the MMCZ as an SDN is sometimes presented by government officials as evidence28 that sanctions apply against Zimbabwe itself and not merely individuals and specified entities. The basis of the argument arises from the fact that section 42 of the Minerals Marketing Corporation of Zimbabwe Act29 requires that all minerals (except silver and gold) are marketed and sold through the MMCZ. The MMCZ must be paid a commission of 0.875% sales. It is thus suggested that no Zimbabwean minerals can be exported to American buyers and non-American buyers are also placed in a difficult position as sanctions prohibit the payment of the commission to the MMCZ. This claim does not withstand scrutiny. Under section 43 of the MMCZ Act, the MMCZ may grant exporters permission to deal directly with buyers, which may then include buyers in the United States. This system appears to be in place with regard most of Zimbabwe’s major exporters, such as those exporting platinum group metals. Buyers pay for these exports directly into sellers’ Zimbabwean nostro accounts, and the MMCZ commission is then paid from these accounts. They are thus unaffected by the listing of MMCZ as a SDN. 25 An Inside Job Zimbabwe: The State, The Security Forces, and a Decade of Disappearing Diamonds Global Witness September 2017. 26 Revised Guidance on Entities Owned By Persons Whose Property and Interests in Property are Blocked Department of the Treasury August 2014. 27 Ministers Lead Zisco Looters The Independent 20.05.05. 28 Recently, at an Extractive Industries Transparency Initiative Conference in Harare on 02.10.19. 29 Chapter 21:04. 9