Abstract
The Foreign Narcotics Kingpin Designation Act was enacted on 3rd December, 1999, as part of the Intelligence Authorization Act for Fiscal Year 2000. The Kingpin Act calls for the imposition of a series of US economic and financial sanctions — with a worldwide reach — on ‘foreign narcotics traffickers’, their related ‘organisations’, and those ‘foreign persons’ who support their activities, enforced by penalties ranging up to fines of $10m and imprisonment for ten years. In passing this legislation, Congress specifically looked to the example provided by an earlier set of economic sanctions that prohibited dealings with Colombian narco‐traffickers or entities which they controlled, established by the President under the International Emergency Economic Powers Act (IEEPA) and administered by the Treasury Department's Office of Foreign Assets Controls (OFAC). The controls established by the Kingpin Act, and the associated Foreign Narcotics Kingpin Sanctions Regulations (FNKSR), accordingly, are neither a unique nor an isolated programme. Rather, they represent the latest step in the evolution of a series of distinct, but related, economic sanctions programmes administered by OFAC.
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