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  • OFAC amends Venezuela-related general licenses

    Financial Crimes

    On September 30, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced amended Venezuelan General Licenses (GL) 3G, which supersedes and replaces GL 3F, and 9F, which supersedes GL 9E. The amended GLs concern authorized transactions related to the financing and dealings in certain bonds and securities, and extend the authorization wind-down periods to March 31, 2020. As previously covered by InfoBytes, the GLs were issued in conjunction with Executive Order 13884 which, among other things, prevents all property and interest in property of the Government of Venezuela within the U.S. or in the possession of a U.S. person from being transferred, paid, exported, withdrawn, or otherwise dealt in.

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

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  • OFAC sanctions additional entities and vessels operating in Venezuela’s oil sector

    Financial Crimes

    On September 24, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13850 against four entities for their alleged involvement in the transportation of oil from Venezuela to Cuba. According to OFAC, the entities’ actions offer support to the Maduro regime and “enable its repressive security and intelligence apparatus.” In addition, OFAC identified four vessels as blocked property owned by the identified entities. As a result of the sanctions, “all property and interests in property of these entities, and of any entities that are owned, directly or indirectly, 50 percent or more by the designated entities, that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.” OFAC notes that its regulations “generally prohibit” U.S. persons from participating in transactions with blocked or designated persons.

    Additionally, the announcement notes that OFAC is delisting two entities in recognition of their actions to ensure that their vessels are not complicit in supporting the Maduro regime. As a result of the delisting, all property and interest of the entities are now unblocked and lawful transactions involving U.S. persons are no longer prohibited.

    Since OFAC’s designation of Venezuela’s state-owned oil company last January, the department has sanctioned several entities and individuals connected to Venezuela’s oil sector. Continuing InfoBytes coverage on these actions can be found here.

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

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  • OFAC sanctions persons linked to corruption network in Venezuela

    Financial Crimes

    On September 17, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13850 against three individuals and 16 entities connected to two previously sanctioned Colombian nationals (covered by InfoBytes here) for enabling the Maduro regime “to corruptly profit from imports of food aid and distribution in Venezuela.” According to OFAC, the designated individuals are immediate family members with business connections to the sanctioned Colombian nationals “who are responsible for or complicit in, or have directly or indirectly engaged in, any deceptive or corrupt transaction or series of transactions with the Government of Venezuela or projects or programs administered by the Government of Venezuela.” The 16 designated entities, OFAC noted, are either owned or controlled by the designated individuals or one of the sanctioned Colombian nationals. As a result of the sanctions, “all property and interests in property of the individuals and entities designated today, and of any entities that are owned, directly or indirectly, 50 percent or more by those individuals or entities, that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.” OFAC noted that its regulations “generally prohibit” U.S. persons from participating in transactions with the designated entities and individuals. OFAC also referred financial institutions to Financial Crimes Enforcement Network advisories FIN-2019-A002, FIN-2017-A006, FIN-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 corrupt foreign political figures and their financial facilitators.

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

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  • OFAC issues new Venezuela-related general license

    Financial Crimes

    On September 9, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License (GL) 34, “Authorizing Transactions Involving Certain Government of Venezuela Persons,” related to Executive Order (E.O.) 13884. As previously covered by InfoBytes, E.O. 13884, among other things, prevents all property and property interests of the Government of Venezuela existing within the U.S. or in the possession of a U.S. person from being transferred, paid, exported, withdrawn, or otherwise dealt in.

    GL 34 authorizes transactions with certain Government of Venezuela individuals, including United States citizens; permanent resident aliens of the United States; individuals in the United States who have a valid U.S. immigrant or nonimmigrant visa, other than individuals in the United States as part of Venezuela’s mission to the United Nations; and former employees and contractors of the Government of Venezuela. OFAC also updated FAQ 680 to reflect the new GL.

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

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  • President Trump issues Executive Order blocking property of the Government of Venezuela

    Financial Crimes

    On August 5, President Trump issued Executive Order (E.O.) 13884 titled “Blocking Property of the Government of Venezuela,” which, among other things, prevents all property and interest in property of the Government of Venezuela existing within the U.S. or in the possession of a U.S. person from being transferred, paid, exported, withdrawn, or otherwise dealt in. E.O. 13884 is being issued in light of the actions of the Maduro regime, “as well as human rights abuses, including arbitrary or unlawful arrest and detention of Venezuelan citizens, interference with freedom of expression, including for members of the media, and ongoing attempts to undermine Interim President Juan Guaido and the Venezuelan National Assembly's exercise of legitimate authority in Venezuela.”

    In connection with the issuance of the E.O, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new and revised FAQs, as well as 12 amended general licenses (General Licenses 2A, 3F, 4C, 7C, 8C, 9E, 10A, 13C, 15B, 16B, 18A, 20A) and 13 new general licenses (General Licenses 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33) related to Venezuela.

    Additionally, OFAC issued new guidance highlighting the U.S. government’s “commitment to the unfettered flow of humanitarian aid to the Venezuelan people.” OFAC notes that its regulations and general licenses allow U.S. persons to continue to provide humanitarian support to the Venezuelan people, including via transactions through the U.S. financial system for authorized activities. OFAC sanctions do not prohibit transactions involving the country or people of Venezuela, provided blocked persons or proscribed conduct are not involved.

    For continuing InfoBytes coverage on Venezuela, including more information on blocked persons or actions, click here.

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

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  • OFAC sanctions corruption network linked to Venezuela’s food subsidy program; DOJ charges two of same individuals for money laundering related to bribery

    Financial Crimes

    On July 25, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against two Colombian nationals responsible for “orchestrating a vast corruption network,” which has enabled former President Maduro and his regime “to significantly profit from food imports and distribution in Venezuela.” According to OFAC, the Colombian nationals created a network comprised of shell companies, business partners, and family members—all of whom have also been designated for their involvement in the network—that illicitly profited from their involvement in Venezuela’s food subsidy program as well as other contracts with the Venezuelan government. The sanctioned network—which also included Maduro’s three stepsons—allegedly “laundered hundreds of millions of dollars in corruption proceeds around the world.” As a result of the sanctions, “all property and interests in property of the individuals and entities designated today, and of any entities that are owned, directly or indirectly, 50 percent or more by those individuals or entities, that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.” OFAC noted that its regulations “generally prohibit” U.S. persons from participating in transactions with the designated entities and individuals. OFAC also referred financial institutions to Financial Crimes Enforcement Network advisories FIN-2019-A002FIN-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.

    The same day, the DOJ announced charges, pursuant to an indictment filed in the U.S. District Court for the Southern District of Florida, against two of the same sanctioned Colombian nationals for money laundering and conspiracy to commit money laundering. The charges relate to the Colombian nationals’ alleged roles in laundering the proceeds of an illegal bribery scheme from bank accounts located in Venezuela to and through bank accounts located in the United States. The bribery scheme resulted in the transfer of approximately $350 million, and allegedly involved contracts to build low-income housing units and efforts to take advantage of Venezuela’s government-controlled exchange rates through the use of “false and fraudulent import documents for goods and materials.”

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

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  • OFAC extends Venezuela-related general license

    Financial Crimes

    On July 26, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced General License (GL) 8B, titled “Authorizing Transactions Involving Petroleos de Venezuela, S.A. (PdVSA) Necessary for Maintenance of Operations for Certain Entities in Venezuela,” which supersedes GL 8A to extend the expiration date through October 25.

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

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

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  • OFAC sanctions four Venezuelan DGCIM officials

    Financial Crimes

    On July 19, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned four officials of Venezuela’s General Directorate of Military Counterintelligence (DGCIM). As previously covered by InfoBytes, the DGCIM was sanctioned by OFAC on July 11, pursuant to Executive Order (E.O.) 13850, for operating in the country’s defense and security sector. According to OFAC, the designations of the four individuals were pursuant to E.O. 13692, following the arrest, physical abuse, and death of a Venezuelan Navy Captain. As a result of the designations, all property and interests in property of the designated persons within U.S. jurisdiction must be blocked and reported to OFAC. OFAC notes that its regulations “generally prohibit” U.S. persons from participating in transactions with these individuals and entities.

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

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  • OFAC sanctions Venezuela’s military counterintelligence agency

    Financial Crimes

    On July 11, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 13850, against the Government of Venezuela’s General Directorate of Military Counterintelligence (DGCIM) for operating in the country’s defense and security sector. According to OFAC, the DGCIM has been involved in human rights abuses and the “politically motivated” arrest and death of a Venezuelan Navy captain. As a result of the sanctions, all property and interests in property of the sanctioned entity or of other entities “that are owned, directly or indirectly, 50 percent or more” by the sanctioned entity “that are in the United States or in the possession or control of U.S. persons 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.

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

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  • OFAC sanctions Cuban oil company for facilitating Maduro regime

    Financial Crimes

    On July 3, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against Cuban state-run oil import and export company for continuing to provide support to the Maduro regime by the importation of oil from Venezuela. The sanctions are pursuant to Executive Order 13850. OFAC alleges that the state-run company has been the recipient of oil from Venezuela and has expanded its operations to include non-traditionally traded oil products. As a result of the sanctions, “all property and interests in property of these individuals, and of any entities that are owned, directly or indirectly, 50 percent or more by such individuals, that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.” OFAC notes that its regulations “generally prohibit” U.S. persons from participating in transactions with these individuals and entities.

    Additionally, the announcement notes that OFAC is delisting an oil tanking company in recognition of the company’s actions to ensure that its vessels are not complicit in supporting the Maduro regime. As a result of the delisting, all property and interest of the company is now unblocked and lawful transactions involving U.S. persons are no longer prohibited.

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

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