Skip to main content
Menu Icon Menu Icon
Close

InfoBytes Blog

Financial Services Law Insights and Observations

Filter

Subscribe to our InfoBytes Blog weekly newsletter and other publications for news affecting the financial services industry.

  • OFAC sanctions four Venezuelan DGCIM officials

    Financial Crimes

    On July 19, the U.S. Treasury Department'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

    Share page with AddThis
  • 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

    Share page with AddThis
  • 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

    Share page with AddThis
  • OFAC sanctions Maduro regime officials in Venezuela

    Financial Crimes

    On June 27 and 28, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated two Maduro regime officials and the son of Maduro for engaging in significant corruption and fraud to the detriment of the people of Venezuela. Specifically, OFAC designated the two regime officials pursuant to Executive Order (E.O.) 13692, for having previously received bribes from two Venezuelan businessmen in exchange for awarding contracts for expensive equipment to maintain Venezuelan electrical infrastructure, which were incompatible with the Venezuelan electrical system. Continued corruption and mismanagement resulted in persistent countrywide blackouts, limiting the people’s access to basic goods, services, and potable water supplies, among other things.

    Additionally, pursuant to E.O. 13692, OFAC designated the son of Maduro for being a current or former official of the Government of Venezuela and a member of Venezuela’s illegitimate National Constituent Assembly, “which seeks to rewrite the Venezuelan constitution and dissolve Venezuelan state institutions, [and] was created through an undemocratic process instigated by Maduro’s government to subvert the will of the Venezuelan people.”

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

    Share page with AddThis
  • OFAC sanctions entity and two individuals for trafficking weapons to IRGC-QF and facilitating sanctions evasion

    Financial Crimes

    On June 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on a resource trading company and its two Iraqi associates, for trafficking “hundreds of millions of dollars’ worth of weapons” to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and facilitating access to the Iraqi financial system to evade sanctions.

    According to OFAC, the sanctions were issued pursuant to Executive Order 13224, which “provides a means by which to disrupt the financial support network for terrorists and terrorist organizations.” As a result, “all property and interests in property of these targets that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.” OFAC noted that persons who engage in transactions with the designated individuals and entities may be exposed to sanctions themselves or subject to enforcement action. Moreover, OFAC warned foreign financial institutions that, unless an exemption applies, they may be subject to U.S. sanctions if they knowingly facilitate significant transactions for any of the designed individuals or entities.

    Financial Crimes Department of Treasury OFAC Executive Order Sanctions Venezuela

    Share page with AddThis
  • 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

    Share page with AddThis
  • 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 Venezuela Sanctions

    Share page with AddThis
  • 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 Venezuela Sanctions OFAC Department of Treasury

    Share page with AddThis
  • 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

    Share page with AddThis
  • 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 Venezuela Sanctions FinCEN

    Share page with AddThis

Pages

Upcoming Events