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  • OFAC amends Venezuela-related general license

    Financial Crimes

    On June 1, the U.S. Treasury Department’s Office of Foreign Assets Control issued Venezuela-related General License (GL) 8H, which authorizes transactions involving Petróleos de Venezuela, S.A. (PdVSA) necessary for the limited maintenance of essential operations in Venezuela or the wind down of operations in Venezuela for certain entities that would otherwise be prohibited by Executive Order 13850, as incorporated into the Venezuela Sanctions Regulations. (Covered by InfoBytes here.) Effective June 1, GL 8H replaces GL 8G, which was issued November 2020.

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

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  • OFAC amends Venezuela-related general license

    Financial Crimes

    On February 2, the U.S. Treasury Department’s Office of Foreign Assets Control issued Venezuela-related General License (GL) 30A, which authorizes certain necessary to port and airport operations that would otherwise be prohibited by Executive Order (E.O.) 13884, as incorporated into the Venezuela Sanctions Regulations. (See previous InfoBytes coverage here.) Effective February 2, G.L. 30A replaces G.L. 30, which was issued in August of 2019.

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

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  • OFAC targets Venezuelan oil sector sanctions evasion network

    Financial Crimes

    On January 19, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13850 against three individuals, fourteen entities, and six vessels for allegedly engaging in activities tied to a Mexico-based network involved in the illicit sale of hundreds of millions of dollars of Venezuelan oil. The action builds on OFAC’s June 2020 sanctions against three individuals and eight foreign entities for allegedly engaging in activities in or associated with a network attempting to evade U.S. sanctions on Venezuela’s oil sector in order to benefit “the illegitimate Maduro regime” and Venezuela’s state-owned oil company, Petroleos de Venezuela, S.A. (covered by InfoBytes here). As a result, all property and interests in property belonging to the identified individuals and entities subject to U.S. jurisdiction are blocked, and “any entities that are owned, directly or indirectly, 50 percent or more by the designated entities, are also blocked.” U.S. persons are generally prohibited from dealing with any property or interests in property of blocked or designated persons.

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

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  • OFAC issues counter terrorism general licenses and related FAQs, updates SDN List

    Financial Crimes

    On January 19, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued four General Licenses in conjunction with State Department designations against a foreign terrorist organization: General License 9, “Official Business of the United States Government,” General License 10, “Official Activities of Certain International Organizations,” General License 11, “Certain Transactions in Support of Nongovernmental Organizations’ Activities in Yemen,” and General License 12, “Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components or Software Updates.” The general licenses authorize certain transactions ordinarily prohibited by the Global Terrorism Sanctions Regulations, Foreign Terrorist Organizations Sanctions Regulations, and Executive Order 13224, including actions “to help facilitate the uninterrupted flow of humanitarian assistance, including COVID-19-related assistance, and certain other critical commodities to the people of Yemen that would otherwise be prohibited pursuant to authorities administered by OFAC.” OFAC also published related FAQs 875, 876, and 877.

    OFAC also updated its Specially Designated Nationals and Blocked Persons List to add individuals and entities associated with Venezuela, Russia, and Yemen designations.

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

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  • OFAC issues amended Venezuela-related general license, sanctions Venezuelan officials

    Financial Crimes

    On January 4, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License (GL) 31A and an amended related frequently asked question. GL 31A authorizes certain transactions and activities involving the IV Venezuelan National Assembly, the Interim President of Venezuela, and certain other persons that would otherwise be prohibited by Executive Order (E.O.) 13884, as incorporated into the Venezuela Sanctions Regulations. (See previous InfoBytes coverage here.)

    Additionally, earlier on December 30, OFAC announced sanctions pursuant to E.O. 13692 against two Venezuelan government officials who presided over the trials of six U.S. persons in Venezuela. According to OFAC, the six executives’ trials “were based on politically motivated charges and marred by a lack of fair trial guarantees.” As a result, all property and interests in property belonging to the identified individuals subject to U.S. jurisdiction are blocked, and “any entities that are owned, directly or indirectly, 50 percent or more by the designated persons are also blocked.” U.S. persons are generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons.

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

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  • OFAC amends Venezuela and Ukraine-related general licenses

    Financial Crimes

    On December 23, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5F, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After July 21, 2021,” which replaces and supersedes GL 5E. OFAC also amended related FAQ 595, which reminds parties that, until July 21, 2021, transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond are prohibited, unless specifically authorized by OFAC.

    Additionally, OFAC concurrently announced the issuance of Ukraine-related GLs 13P and 15J. GL 13P, “Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in GAZ Group,” is effective December 23 and replaces and supersedes GL 13O. Additionally, GL 15J, “Authorizing Certain Activities Involving GAZ Group,” is also effective on December 23 and replaces and supersedes GL 15I.

    Financial Crimes OFAC Venezuela Ukraine Of Interest to Non-US Persons Sanctions

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  • OFAC sanctions biometric technology company for supporting Maduro regime

    Financial Crimes

    On December 18, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against a Venezuelan-registered biometric technology company and two individuals for allegedly materially supporting the Maduro regime by providing goods and services that the regime used to carry out the “fraudulent” elections on December 6. The sanctions, issued pursuant to Executive Order 13692, reflect Treasury’s continued efforts to hold persons who offer support to the Maduro regime accountable. As a result, all property and interests in property belonging to the identified individuals subject to U.S. jurisdiction are blocked, and “any entities that are owned, directly or indirectly, 50 percent or more by the designated individuals, are also blocked.” U.S. persons are generally prohibited from dealing with any property or interests in property of blocked or designated persons.

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

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  • OFAC sanctions Chinese tech company for supporting Maduro regime

    Financial Crimes

    On November 30, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against a Chinese technology company for allegedly “having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, actions or policies that undermine democratic processes or institutions.” The sanctions, issued pursuant to Executive Order (E.O.) 13692, reflect Treasury’s continued efforts to hold persons who offer support to the Maduro regime accountable. As a result, all property and interests in property belonging to the identified individuals subject to U.S. jurisdiction are blocked, and “any entities that are owned, directly or indirectly, 50 percent or more by the designated individuals, are also blocked.” U.S. persons are generally prohibited from dealing with any property or interests in property of blocked or designated persons.

    Concurrently, OFAC issued Venezuela-related General License (GL) 38 and a related frequently asked question. GL 38 authorizes the wind down of transactions and activities involving the sanctioned company or any entity owned—directly or indirectly at a 50 percent or greater interest—through January 14, 2021, which would otherwise be prohibited by E.O. 13692. According to OFAC, GL 38 does not authorize (i) any debit to the sanctioned entity’s accounts on a U.S. financial institution’s books; or (ii) any transactions otherwise prohibited by the Venezuela Sanctions Regulations.

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

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  • OFAC issues amended Venezuela-related general license

    Financial Crimes

    On November 17, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Venezuela General License (GL) 8G, “Authorizing Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Necessary for the Limited Maintenance of Essential Operations in Venezuela or the Wind Down of Operations in Venezuela for Certain Entities.” GL 8G supersedes GL 8F and extends the expiration date for certain authorizations through June 3, 2021 that would otherwise be prohibited under Executive Orders 13850, 13857, or 13884.

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

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

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  • OFAC sanctions entities for Iranian petrochemical sales

    Financial Crimes

    On October 29, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13846 against eight entities for their alleged “involvement in the sale and purchase of Iranian petrochemical products brokered by [a petrochemical company]. . .designated by Treasury in January 2020.” The designated entities—based in Iran, China, and Singapore—allegedly aided the petrochemical company’s efforts to process and move funds generated by the sale of these products, which were then used to finance the Iranian regime’s “destabilizing agenda of support to corrupt regimes and terrorist groups throughout the Middle East and, more recently, Venezuela.”

    In addition, OFAC also updated its List of Specially Designated Nationals and Blocked Persons to add additional aliases for an Iraq-based bank that was previously designated, among other things, for being “used by Iran’s Central Bank Governor to covertly funnel millions of dollars on behalf of the IRGC-QF to support Hizballah.”

    As a result, all property and interests in property belonging to, or owned by, the designated persons subject to U.S. jurisdiction are blocked, and U.S. persons are also “generally prohibited from engaging in transactions with them.” OFAC further warned foreign financial institutions that knowingly facilitating significant transactions or providing significant support to the designated persons may subject them to sanctions that terminate their access to the U.S. financial system.

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

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