A reported filing under the United States’ Foreign Agents Registration Act (FARA) has drawn sharp focus to the intersection of U.S. sanctions law and a US$250,000 lobbying contract linked to a Guyanese political movement founded by a sanctioned businessman.
Documents circulating online — said to have been filed with the U.S. Department of Justice on Feb. 24 — list We Invest in Nationhood (WIN) as the foreign principal and identify Wyoming-based LGS LLC as the lobbying firm retained to provide strategic advisory services in the United States. The filing names Stephen Payne and Logan Somera as the lobbyists engaged to help cultivate relationships within the U.S. government and private sector.
The central issue is not the FARA registration itself — which is a legal disclosure requirement for foreign principals engaging U.S. lobbyists — but whether the reported engagement is consistent with U.S. sanctions restrictions.
WIN was founded by Azruddin Mohamed, who, along with his father Nazar Mohamed and several associated businesses, was sanctioned in 2024 by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Under OFAC regulations, U.S. persons are generally prohibited from engaging in transactions with designated individuals unless authorized by license.
If the reported US$250,000 contract was directly or indirectly financed by a sanctioned individual, legal experts say it could raise compliance concerns under U.S. sanctions law.
“Once a person is designated, U.S. entities must block property and are typically barred from providing services,” said one regional sanctions compliance specialist, speaking anonymously due to the legal sensitivity of the matter. “A lobbying contract is a service. The key question becomes whether any authorization or exemption applies.”
Neither WIN nor LGS LLC has publicly clarified the structure of the reported payment, whether funds were routed through third parties, or whether a license was sought from OFAC.
The controversy unfolds as Azruddin and Nazar Mohamed face extradition proceedings in Guyana following a 2025 indictment by a U.S. federal grand jury in Miami on charges including money laundering, mail fraud and wire fraud. The Mohameds have denied wrongdoing.
Under U.S. law, FARA filings are public disclosures and do not imply criminal conduct. However, if a designated individual funded a lobbying engagement without appropriate authorization, it could expose U.S.-based participants to potential regulatory scrutiny.
As questions mount over the source and legality of the reported funds, the focus has narrowed to one issue: how a sanctioned political founder could lawfully finance a quarter-million-dollar contract with a U.S. lobbying firm under existing sanctions restrictions.
Clarification from U.S. authorities or the parties involved may ultimately determine whether the transaction was compliant — or whether it presents broader legal and diplomatic implications.