On November 10, 2021, President Biden signed the Reinforcing Nicaragua’s Adherence to Conditions for Electoral Reform Act (“the RENACER Act”) into law, which calls for increased sanctions against Nicaragua.  This followed November 7 elections in Nicaragua that allowed President Daniel Ortega to stay in power for a fourth consecutive term.  President Biden had issued a statement referring to the November 7 elections as “a pantomime election that was neither free nor fair.”

The RENACER Act authorizes sanctions on parties involved in unfair elections or corruption in Nicaragua.  It also includes initiatives to address potential corruption, human rights abuses, and curtailment of press freedom.  For example, the RENACER Act calls for a series of reports, including reports on alleged corruption by the Ortega family and government officials, human rights abuses by Nicaraguan security forces, strategies for supporting press freedom in Nicaragua, and Russian activities in Nicaragua, including Russian military sales to Nicaragua.

The RENACER Act also requires the Secretary of State and the Secretary of the Treasury to develop and implement a unified strategy to align diplomatic efforts and the use of sanctions to promote free, fair, and transparent elections in Nicaragua.  It calls for increased coordination with Canada, the European Union, and governments in Latin America and the Caribbean to impose such measures. It is unclear what additional sanctions would be imposed pursuant to the RENACER Act.  For background, in March 2020, in response to US Government concerns regarding human rights abuses in Nicaragua, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) imposed sanctions on the Nicaraguan National Police (“NNP”) and three NNP commissioners, citing serious human rights abuses (please see our prior blog post on these designations here).  In June 2021, four Nicaraguans, including Ortega’s daughter, were sanctioned for allegedly undermining democracy and contributing to human rights abuses in Nicaragua.  Under the RENACER Act, sanctions measures, if any, would likely focus on individuals and government-controlled companies deemed to be responsible for unfair elections, corruptions, human rights abuses, and restrictions on press freedom. This is an evolving landscape, and we continue to monitor related development and may provide further updates.

The authors acknowledge the assistance of Vivian Tse on this blog post.


Ms. Contini focuses her practice on export controls, trade sanctions, and anti-boycott laws. This includes advising US and multinational companies on trade compliance programs, risk assessments, licensing, review of proposed transactions and enforcement matters. Ms. Contini works regularly with companies across a wide range of industries, including the pharmaceutical/medical device, oil and gas, and nuclear sectors.


Eunkyung advices clients on various regulatory compliance and trade issues, concentrating on the US export controls such as the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR), economic and trade sanctions, US customs and import laws, the US Foreign Corrupt Practices Act (FCPA), and foreign anti-bribery laws.