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  • OFAC sanctions Venezuela’s state gold mining company and its president for assisting Maduro regime

    Financial Crimes

    On March 19, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against Venezuela’s state-owned metals mining company and the company’s president pursuant to Executive Order 13850. According to OFAC, the designations target the “illicit gold operations that have continued to prop up the illegitimate regime of former President Nicolas Maduro.” As a result, all property and interests in property of the sanctioned entity and individual, and of any entities owned 50 percent or more by them, which are 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. OFAC’s announcement referred to Financial Crimes Enforcement Network advisories FIN-2017-A006 and FIN-2017-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.

    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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  • OFAC issues continued extension of Venezuela-related General Licenses

    Financial Crimes

    On March 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) amended two General Licenses (GL) to extend the expiration date of previous Venezuela-based GLs to May 10 for certain provisions related to sanctions issued against Venezuela’s state-owned oil company pursuant to Executive Order 13850. GL 3D, which supersedes GL 3C, authorizes transactions necessary to wind down financial contracts, and transactions related to, provision of financing for, and other dealings in certain bonds, provided the divestment or transfer (including the facilitation) of any holdings of these bonds are to a non-U.S. person. GL 9C, which supersedes GL 9B, authorizes certain transactions related to securities issued prior to August 25, 2017 by the oil company and its subsidiaries. Additionally, OFAC issued correspondingly revised FAQs 661 and 662 to provide additional clarification on expected levels of due diligence, as well as implications for U.S. and non-U.S. persons.

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

    Financial Crimes Of Interest to Non-US Persons Venezuela Sanctions

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  • OFAC sanctions Russian bank for providing assistance to Venezuelan oil company

    Financial Crimes

    On March 11, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against a Moscow-based bank for materially assisting Venezuela’s state-owned oil company, which was sanctioned earlier this year by OFAC pursuant to Executive Order 13850. (See previous InfoBytes coverage here.) The bank, which is jointly owned by Russian and Venezuelan state-owned companies, “materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of,” the previously sanctioned entity. According to OFAC, the bank was also identified as “the primary international financial institution willing to finance” the Venezuelan cryptocurrency, Petro, which was allegedly created to help former President Maduro’s regime circumvent U.S. sanctions. As a result, any assets or interests therein belonging to the bank, as well as any entities directly or indirectly owned 50 percent or more by the bank that are subject to U.S. jurisdiction are blocked and must be reported to OFAC. U.S. persons are also prohibited generally from dealing with any such property or interests.

    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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  • OFAC sanctions Venezuelan security officials connected to Maduro regime

    Financial Crimes

    On March 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against six Venezuelan security officials connected to former President Maduro’s “illegitimate regime.” According to OFAC, the sanctions, taken pursuant to Executive Order 13692, designate the individuals in response to actions taken by groups under their control that have obstructed the delivery of humanitarian aid. As a result, any assets or interests therein belonging to the identified individuals, as well as any entities directly or indirectly owned 50 percent or more by such individuals that are subject to U.S. jurisdiction are blocked and must be reported to OFAC. U.S. persons are also prohibited generally from dealing with any such property or interests. OFAC also refers financial institutions to Financial Crimes Enforcement Network advisories FIN-2017-A006 and FIN-2017-A003 for further information concerning the use of the U.S. financial system and real estate market by Venezuelan government agencies and individuals to launder corrupt proceeds.

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

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

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  • OFAC sanctions Venezuelan governors aligned with Maduro regime

    Financial Crimes

    On February 25, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against four Venezuelan governors connected to former President Maduro’s “illegitimate regime.” According to OFAC, the sanctions, taken pursuant to Executive Order 13692, designate the individuals for engaging in “endemic corruption” and allegedly “blocking the delivery of critical humanitarian aid.” As a result, any assets or interests therein belonging to the identified individuals—along with any entities directly or indirectly owned 50 percent or more by such individuals—subject to U.S. jurisdiction are blocked and must be reported to OFAC. U.S. persons are also prohibited generally from dealing with any such property or interests. In addition, OFAC refers financial institutions to Financial Crimes Enforcement Network advisories FIN-2017-A006 and FIN-2017-A003 for further information concerning the use of the U.S. financial system and real estate market by Venezuelan government agencies and individuals to launder corrupt proceeds.

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

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

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  • OFAC sanctions officials aligned with Maduro regime

    Financial Crimes

    On February 15, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced additions to the Specially Designated Nationals List pursuant to Executive Order 13692. OFAC’s additions to the list include five current or former officials connected to former President Maduro, including the president of Venezuela’s state-owned oil company, which was sanctioned at the end of January. (See previous InfoBytes coverage here.) According to OFAC, the designated individuals have engaged in “significant corruption and fraud against the people of Venezuela,” and continue to assist the Maduro regime’s repression of Venezuelan people. As a result, any assets or interests therein belonging to the identified individuals—along with any entities directly or indirectly owned 50 percent or more by such individuals—subject to U.S. jurisdiction are blocked and must be reported to OFAC. U.S. persons are prohibited generally from dealing with any such property or interests.

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

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

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  • OFAC amends Venezuela-related General Licenses and FAQs on sanctioned oil company

    Financial Crimes

    On February 11, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) amended two General Licenses (GL) and issued three revised FAQs regarding sanctions against Venezuela’s state-owned oil company pursuant to Executive Order 13850. GL 3C, which supersedes GL 3B, authorizes transactions related to, provision of financing for, and other dealings in certain bonds, provided the divestment or transfer (including the facilitation) of any holdings of these bonds are to a non-U.S. person. GL 9B, which supersedes GL 9A, authorizes certain transactions related to securities issued prior to August 25, 2017 by the oil company and its subsidiaries. Additionally, OFAC issued revised FAQs 650, 661, and 662 to provide additional clarification on expected levels of due diligence, as well as implications for U.S. and non-U.S. persons.

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

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

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  • OFAC revises Venezuela-related General Licenses on sanctioned oil company, issues new FAQs

    Financial Crimes

    On February 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) amended two General Licenses (GL) and issued two new FAQs regarding sanctions against Venezuela’s state-owned oil company pursuant to Executive Order 13850.

    OFAC amended GL 3B to authorize transactions related to, provision of financing for, and other dealings in certain bonds. GL 9A, which supersedes GL 9, authorizes certain transactions related to securities issued prior to August 25, 2017 by the oil company and its subsidiaries. GL 9A and related FAQ 661 clarify that trades in the oil company’s securities placed prior to 4:00 pm EST on January 28, 2019, are generally authorized “to settle in the ordinary course, irrespective of whether the sale or transfer is to a non-U.S. person.”

    Visit here for additional InfoBytes coverage of Venezuela actions.

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

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  • OFAC announces sanctions against Venezuela’s state-owned oil company; President Trump issues related Executive Order

    Financial Crimes

    On January 28, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against Venezuela’s state-owned oil company pursuant to Executive Order 13850 (E.O. 13850). According to OFAC, the designation follows a determination made by the Secretary of the Treasury that persons who operate in the oil sector of the Venezuelan economy are subject to sanctions pursuant to E.O. 13850, which was issued in order to “help prevent further diverting of Venezuela’s assets by Maduro and preserve these assets for the people of Venezuela.” As a result, all assets belonging to the company subject to U.S. jurisdiction are blocked, and U.S. persons generally are prohibited from dealing with the company. However, OFAC concurrently issued eight new General Licenses (GL), and amended GL 3, in order to authorize certain transactions with the company and identified subsidiaries, including those necessary to wind down operations or existing contracts. Specifically, GL 7 and GL 12 permit Venezuelan oil to be imported into the U.S. through April 28, provided any payments made to the company or its majority-owned subsidiaries (minus certain identified exceptions) be made into a blocked, interest-bearing account located in the U.S.

    In a separate action the same day, President Trump issued an Executive Order to, among other things, expand the definition of “Government of Venezuela” to include the Central Bank of Venezuela, the state-owned oil company, and “any person who has acted or purported to act directly or indirectly for or on behalf of” the Government of Venezuela, including members of the Maduro regime. The E.O. is issued in conjunction with E.O.s 13692, 13808, 13827, 13835, and 13850. In connection with the issuance of the new E.O., OFAC published a FAQ explaining E.O.’s impact on Venezuela-related sanctions, which all remain in effect.

    Visit here for additional InfoBytes coverage of Venezuela actions and E.O.s.

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

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  • OFAC adds illicit foreign exchange operation participants to Specially Designated Nationals List; issues Venezuela-related General License and new FAQ

    Financial Crimes

    On January 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced additions to the Specially Designated Nationals List pursuant to Executive Order 13850. OFAC’s additions to the list include seven individuals—including former Venezuelan government officials—and 23 entities for their participation in a bribery scheme involving the Venezuelan Office of the National Treasury in order to conduct illicit foreign exchange operations in the country. According to OFAC, the designated persons engaged in transactions involving deceptive practices and corruption, including wiring payments that were “hidden behind a sophisticated network of U.S. and foreign companies that hid the individuals’ beneficial ownership.” As a result, all assets belonging to the identified individuals and entities subject to U.S. jurisdiction are blocked, and U.S. persons generally are prohibited from dealing with them.

    Concurrently, OFAC issued Venezuela-related General License 6 (GL 6) to allow U.S. persons to engage in otherwise prohibited wind-down transactions with two of the designated companies through January 8, 2020. Specifically, GL 6 authorizes certain activities with the designated companies relating to the maintenance and wind-down of operations, contracts, and agreements that were effective prior to January 8, 2019. OFAC also published a new FAQ to provide additional guidance on the types of activities considered “maintenance” under GL 6.

    As FCPA Scorecard previously reported, the owner was indicted under seal in August for conspiracy to violate the FCPA, conspiracy to commit money laundering, and nine counts of money laundering.

    Visit here for additional InfoBytes coverage on Venezuela sanctions.

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

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