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  • OFAC amends three Venezuela-related General Licenses

    Financial Crimes

    On June 6, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) amended three General Licenses (GL), (i) GL 7B, which supersedes GL 7A; (ii) GL 8A, which supersedes GL 8; and (iii) GL 13A, which supersedes GL 13, to clarify that these general licenses do not authorize transactions or dealings related to the exportation or re-exportation of diluents, directly or indirectly, to Venezuela. Additionally, OFAC is issuing corresponding FAQ 672 to provide further guidance with respect to restrictions regarding diluents.

    Visit here for additional InfoBytes coverage of actions related to Venezuela.

    Financial Crimes Venezuela Of Interest to Non-US Persons Sanctions

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  • Executive pleads guilty in oil company bribery case

    Financial Crimes

    On May 29, the DOJ announced that a dual U.S.-Venezuelan citizen pleaded guilty for his role in a bribery scheme involving oil and natural gas company officials. The citizen pleaded guilty in the Southern District of Texas to conspiracy to violate the FCPA, violating the FCPA, and failing to report foreign bank accounts. His sentencing is set for August 28.

    He controlled multiple U.S. and international companies that provided goods and services to the company. According to the DOJ, the citizen and a co-conspirator paid at least $629,000 in bribes to a former company official in exchange for favorable business treatment for his companies. Prior FCPA Scorecard coverage is available here.

    Financial Crimes DOJ FCPA Bribery

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  • OFAC imposes additional oil sector sanctions connected to Venezuela’s defense and intelligence sector

    Financial Crimes

    On May 10, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against two companies for their alleged involvement in the transportation of oil from Venezuela to Cuba, which provides support to former President Maduro’s defense and intelligence sector. In addition, OFAC identified two vessels as blocked property owned by the identified companies. According to the Treasury Secretary Steven T. Mnuchin, “[OFAC’s] action today puts Venezuela’s military and intelligence services, as well as those who support them, on notice that their continued backing of the illegitimate Maduro regime will be met with serious consequences.” As a result, all property and interests in property of the sanctioned entities or of other entities that are owned at least 50 percent by the sanctioned entities, that are either in the United States or in the possession or control of a U.S. person, are blocked and must be reported to OFAC. U.S. persons are also generally prohibited from entering into transactions with these entities. Furthermore, OFAC also referred financial institutions to Financial Crimes Enforcement Network advisories FIN-2019-A002, FIN-2017-A006, and FIN-2018-A003 for further information concerning the efforts of Venezuelan government agencies and individuals to use the U.S. financial system and real estate market to launder corrupt proceeds, as well as human rights abuses connected to corrupt foreign political figures and their financial facilitators.

    Visit here for continuing InfoBytes coverage of actions related to Venezuela.

    Financial Crimes OFAC Department of Treasury Sanctions Of Interest to Non-US Persons Venezuela

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  • OFAC lifts sanctions on former high-ranking Venezuelan official

    Financial Crimes

    On May 7, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced it removed sanctions imposed on a former high-ranking Venezuelan official in the Maduro regime after he broke ties with the regime. As previously covered by InfoBytes, the sanctions were imposed in February of this year pursuant to Executive Order (E.O.) 13692. As a result of the removal, any otherwise lawful transactions involving U.S. persons and the individual are no longer prohibited. OFAC emphasized that the action “demonstrates that U.S. sanctions need not be permanent and are intended to bring about a positive change of behavior,” and further “shows the good faith of the [U.S.] that removal of sanctions may be available for designated persons who take concrete and meaningful actions to restore democratic order, refuse to take part in human rights abuses, speak out against abuses committed by the illegitimate Maduro regime, or combat corruption in Venezuela.”

    Financial Crimes Department of Treasury Of Interest to Non-US Persons OFAC Executive Order Sanctions Venezuela

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  • Updated FinCEN advisory warns of continued Venezuelan money laundering attempts

    Financial Crimes

    On May 3, the Financial Crimes Enforcement Network (FinCEN) issued an updated advisory to warn financial institutions of continued public corruption and attempted money laundering related to Venezuelan government agencies and political figures. The advisory updates a September 2017 advisory (previously covered by InfoBytes here) and renews the description of public corruption in Venezuela. The advisory also describes how “corrupt Venezuelan senior political figures exploit a Venezuelan government-administered food program by directing overvalued, no-bid contracts to co-conspirators that use ‘an over-invoicing trade-based money laundering’” scheme, which involves, among other things, front or shell companies, non-dollar denominated accounts, and nested accounts designed to evade sanctions and anti-money laundering/countering the financing of terrorism (AML/CFT) controls. The advisory also notes attempts by former President Maduro’s regime to evade sanctions and AML/CFT controls through the use of digital currency. The update provides revised financial red flags to assist with the identification and reporting of suspicious activity to FinCEN in connection with senior Venezuelan political figures.

    FinCEN further emphasizes that financial institutions should continue to follow a risk-based approach and that normal transactions involving Venezuelan business and nationals are not necessarily reflective of the aforementioned risks.

    See here for continuing InfoBytes coverage of actions related to Venezuela.

    Financial Crimes FinCEN Bank Secrecy Act Anti-Money Laundering Venezuela Of Interest to Non-US Persons Combating the Financing of Terrorism

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  • OFAC sanctions Venezuelan officials connected to Maduro regime

    Financial Crimes

    On April 26, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against the two individuals identified as current or former officials of the Government of Venezuela for providing support to former President Maduro’s regime. Financial Crimes Enforcement Network advisories FIN-2017-A006, FIN-2017-A003, and FIN-2018-A003 provide additional information concerning the efforts of Venezuelan government agencies and individuals to use the U.S. financial system and real estate market to launder corrupt proceeds, as well as human rights abuses connected to foreign political figures and their financial facilitators. As a result, all property and interests in property of the sanctioned individuals, and of any entities owned 50 percent or more by them subject to U.S. jurisdiction, are blocked and must be reported to OFAC. U.S. persons are generally prohibited from entering into transactions with designated persons. 

    Visit here for continuing InfoBytes coverage of actions related to Venezuela.

    Financial Crimes OFAC Department of Treasury Sanctions Of Interest to Non-US Persons Venezuela

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  • Treasury sanctions Venezuela’s central bank and official connected to Maduro regime; sanctions Nicaraguan bank and official

    Financial Crimes

    On April 17, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against Venezuela’s central bank, along with an individual determined to be a current or former official of the Government of Venezuela, for providing support to former President Maduro’s regime. OFAC states that the U.S. “has taken steps to ensure that regular debit and credit card transactions can proceed and personal remittances and humanitarian assistance continue unabated and are able to reach those” affected by the humanitarian crisis in Venezuela. Financial Crimes Enforcement Network advisories FIN-2017-A006, FIN-2017-A003, and FIN-2018-A003 provide additional information concerning the efforts of Venezuelan government agencies and individuals to use the U.S. financial system and real estate market to launder corrupt proceeds, as well as human rights abuses connected to foreign political figures and their financial facilitators. OFAC concurrently issued amendments to existing Venezuela-related general licenses as well as two new general licenses in connection with the designations, including “authorizations to ensure that U.S. persons may continue to engage in and facilitate non-commercial, personal remittances and the provision of humanitarian assistance to the people of Venezuela.”

    Additionally the same day, OFAC designated the Nicaraguan president’s son along with a Nicaraguan bank for actions supporting the Ortega regime. According to OFAC, the bank has, among other things, provided material, technical, and financial support to the previously sanctioned vice president, as well as money laundering assistance to the regime. OFAC also cited to the president’s son’s involvement with foreign investors to provide “preferential access to the Nicaraguan economy.” As a result, all property and interests in property of the sanctioned entities and individuals, and of any entities owned 50 percent or more by them subject to U.S. jurisdiction, are blocked and must be reported to OFAC. U.S. persons are also generally prohibited from entering into transactions with the sanctioned entities and individuals. 

    Financial Crimes Of Interest to Non-US Persons OFAC Department of Treasury Venezuela Nicaragua Sanctions

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  • OFAC imposes additional oil sector sanctions against companies connected to Maduro regime

    Financial Crimes

    On April 12, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against four companies for their alleged involvement in the transportation of oil from Venezuela to Cuba. According to OFAC, the companies’ actions offer support to former President Maduro’s regime and contribute to the humanitarian crisis in Venezuela. In addition, OFAC identified nine vessels as blocked property owned by the identified companies. As a result, all property belonging to the sanctioned entities, and interests in property of the sanctioned entities (or of any entities owned 50 percent or more by them) subject to U.S. jurisdiction are blocked and must be reported to OFAC. U.S. persons are also generally prohibited from entering into transactions with them. Furthermore, OFAC also referred financial institutions to Financial Crimes Enforcement Network advisories FIN-2017-A006FIN-2017-A003, and FIN-2018-A003 for further information concerning the efforts of Venezuelan government agencies and individuals to use the U.S. financial system and real estate market to launder corrupt proceeds, as well as human rights abuses connected to foreign political figures and their financial facilitators.

    Visit here for continuing InfoBytes coverage of actions related to Venezuela.

    Financial Crimes Of Interest to Non-US Persons OFAC Department of Treasury Settlement Cuba Venezuela Sanctions

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  • U.K. subsea services company and subsidiaries to pay $440,000 for Cuban and Iranian sanctions violations

    Financial Crimes

    On April 11, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced two settlements totaling more than $440,000 with a U.K. subsea services company and certain subsidiaries that operate in the oil and gas industry. The first settlement, for $227,500, resolves potential civil liability for seven alleged violations of the Cuban Assets Control Regulations (CACR). According to OFAC, two of the company/subsidiaries’ Malaysian affiliates produced analytical reports and conducted workshops for oil well drilling projects in Cuban territorial waters related to projects managed by companies including Venezuela’s state-owned oil company, which was previously designated by OFAC in January (see InfoBytes coverage here). OFAC considered various aggravating factors—including that the alleged violations constitute an egregious case—and noted that the company/subsidiaries “willfully violated U.S. sanctions laws and regulations when they knowingly dealt with Cuban interests despite prior notification of their unlawfulness.” OFAC also noted that senior managers “deliberately concealed their dealings with Cuba on multiple occasions.” OFAC considered numerous mitigating factors, including the company/subsidiaries’ voluntarily self-disclosure of the apparent violations and remedial efforts taken to avoid similar violations from occurring in the future.

    The same day OFAC announced a second settlement, this time for $213,866, which resolves potential civil liability for 13 alleged CACR violations. The settlement also resolves three alleged violations of the Iranian Transactions and Sanctions Regulations (ITSR) by the company’s U.S.-based investor-parent company. According to OFAC, the company issued sanctions compliance guidance to all of its subsidiaries with instructions that transactions with Cuba and Iran (including indirect third parties) were prohibited. However, certain subsidiaries disregarded the guidance and allegedly engaged in transactions within Cuban and Iranian territorial waters. In reaching the settlement amount, OFAC determined, among other things, that (i) the company voluntarily self-disclosed the apparent violations; (ii) the alleged violations constitute a non-egregious case; (iii) the subsidiaries have confirmed the conduct has been terminated; and (iv) remedial efforts have been undertaken to minimize the risk of similar violations from occurring in the future.

    Financial Crimes Of Interest to Non-US Persons OFAC Department of Treasury Settlement Cuba Iran Sanctions

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  • OFAC sanctions companies for transporting Venezuelan oil to Cuba

    Financial Crimes

    On April 5, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against two non-U.S. companies for their alleged involvement in the transportation of oil from Venezuela to Cuba. According to OFAC, the companies have engaged in a “barter system,” in which Venezuelan oil supplies are exchanged for Cuban assistance in the form of “political advisors, intelligence and military officials, and medical professionals. . . all of whom” prop up “the illegitimate Maduro regime through oil-for-repression schemes as [an] attempt to keep Maduro in power.” 

    Visit here for continuing InfoBytes coverage of actions related to Venezuela.

    Financial Crimes Of Interest to Non-US Persons Venezuela Sanctions OFAC Department of Treasury

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