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  • OFAC expands Venezuelan and Iranian sanctions

    Financial Crimes

    On January 5, the Treasury Department’s Office of Foreign Assets Control (OFAC) imposed additional sanctions against four current or former officials of the Venezuelan government. The designations, issued pursuant to Executive Order 13692, identify officials who are “associated with corruption and repression in Venezuela” and have “forsaken the professional republican mission of the military institution, which . . . is to be ‘with no political orientation … and in no case at the service of any person or political partisanship.’” All assets belonging to the identified individuals subject to U.S. jurisdiction are frozen, and U.S. persons are generally prohibited from dealing with them. See here for previous InfoBytes coverage of Venezuelan sanctions.

    Separately on January 4, OFAC designated five Iranian entities, pursuant to Executive Order 13382 (E.O. 13382), for their ties to Iran’s ballistic missile program. The five entities identified in the designation are either owned or controlled by an Iranian group that is “responsible for the development and production of Iran's solid-propellant ballistic missiles, is listed in the Annex to E.O. 13382 and is currently sanctioned by the U.S., UN, and EU.” In addition to freezing assets subject to U.S. jurisdiction and prohibiting U.S. persons from engaging in transactions with the entities, “foreign financial institutions that knowingly facilitate significant transactions for, or persons that provide material or certain other support to, the entities designated today risk exposure to sanctions that could sever their access to the U.S. financial system or block their property and interests in property under U.S. jurisdiction.” See here for previous InfoBytes coverage of Iranian sanctions.

    Financial Crimes Department of Treasury OFAC Sanctions International Executive Order

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  • OFAC Sanctions Ten Additional Venezuelan Officials Connected to Venezuela’s Electoral Process

    Financial Crimes

    On November 9, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sanctions against ten current or former officials of the government of Venezuela for “undermining electoral processes, media censorship, or corruption in government-administered food programs in Venezuela.”  The designation follows October 15, 2017 state elections in Venezuela, which were “marked by numerous irregularities that strongly suggest fraud helped the ruling party unexpectedly win a majority of governorships.”  Under the sanctions, issued pursuant to Executive Order 13692 (see previous InfoBytes coverage here), all assets belonging to the identified individuals subject to U.S. jurisdiction are frozen, and U.S. persons are prohibited from having any dealings with them.

    See additional InfoBytes coverage on previously issued Venezuelan sanctions here and here.

    Financial Crimes Department of Treasury OFAC Sanctions

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  • President Trump Imposes Additional Venezuelan Sanctions

    Financial Crimes

    On August 24, President Trump announced the issuance of new sanctions against Venezuela. Executive Order 13808 “Imposing Additional Sanctions with Respect to the Situation in Venezuela,” adds additional restrictions to those declared in Executive Order 13692. The sanctions prohibit transactions related to the following:

    • “new debt with a maturity of greater than 90 days” in conjunction with the Venezuelan state-owned oil and natural gas company (state-owned company);
    • “new debt with a maturity of greater than 30 days, or new equity, of the Government of Venezuela, other than debt” in conjunction with the state-owned company;
    • “bonds issued by the Government of Venezuela prior to the effective date of this order”;
    • “dividend payments or other distributions of profits to the Government of Venezuela from any entity owned or controlled, directly or indirectly, by the Government of Venezuela;
    • “[t]he purchase, directly or indirectly, by a [U.S.] person or within the [U.S.], of securities from the Government of Venezuela, other than securities qualifying as new debt with a maturity of less than or equal to 90 days [for state-owned company debt] or 30 days [for other Government of Venezuela debt].”

    On August 25, OFAC also issued four General Licenses containing additional provisions: (i) General License 1 imposes a wind-down period through September 24, 2017 for contracts and other agreements that were effective prior to the Executive Order's effective date; (ii) General License 2 authorizes certain transactions involving a specifically listed holding company; (iii) General License 3 authorizes dealings in certain specified Government of Venezuela-related bonds that would otherwise be prohibited; and (iv) General License 4 allows new debt transactions related to “the provision of financing for, and other dealings in new debt related to the exportation or reexportation, from the [U.S.] or by a U.S. person . . . of agricultural commodities, medicine, medical devices, or replacement parts and components for medical devices,” provided compliance with the outlined requirements and limitations. OFAC also published answers to several related frequently asked questions concerning the additional sanctions.

    Financial Crimes OFAC Sanctions Department of Treasury

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  • OFAC Imposes Sanctions on Eight Additional Venezuelans Connected to Venezuelan President Maduro

    Financial Crimes

    On August 9, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it was imposing sanctions on eight Venezuelan individuals for their role in supporting the “Constituent Assembly,” which was instituted under President Nicolas Maduro in order to allegedly undermine the democratic process by “rewrit[ing] the Venezuelan constitution and dissolv[ing] Venezuelan state institutions.” Seven of the individuals sanctioned are current or former officials of the Venezuelan government, and one was an active participant in identified “anti-democratic” actions. All assets belonging to the identified individuals subject to U.S. jurisdiction are frozen, and U.S. persons are prohibited from having any dealings with them. As previously reported in InfoBytes, sanctions were imposed on President Maduro on July 31.

    Financial Crimes Sanctions Department of Treasury OFAC

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  • OFAC Imposes Sanctions on Venezuelan President Maduro

    Financial Crimes

    On July 31, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it was imposing sanctions on Venezuelan President Nicolás Maduro, pursuant to Executive Order 13692, for undermining the country’s democracy and rule of law after recent elections and committing widespread human rights abuses. The sanctions prohibit any U.S. individual from dealing with President Maduro and freezes all assets belonging to him subject to U.S. jurisdiction. Treasury Secretary Steven T. Mnuchin explained that the July 30 “illegitimate elections confirm that Maduro is a dictator who disregards the will of the Venezuelan people. By sanctioning Maduro, the United States makes clear our opposition to the policies of his regime and our support for the people of Venezuela who seek to return their country to a full and prosperous democracy.”

    The July 31 sanctions follow an announcement on July 26 in which OFAC announced it was imposing sanctions against 13 current or former Venezuelan government officials associated with election corruption and human rights violations. As a result, all assets subject to U.S. jurisdiction are frozen and U.S. persons are prohibited from dealing with any of the individuals on the list.

    Financial Crimes Sanctions OFAC Department of Treasury

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  • OFAC Publishes Venezuela Sanctions Regulations

    Federal Issues

    On July 10, OFAC published regulations to implement the Venezuela Defense of Human Rights and Civil Society Act of 2014 and Executive Order 13692. The Act required the President to impose targeted sanctions on certain persons determined to be responsible for significant acts of violence or serious human rights abuses against antigovernment protesters in Venezuela, and to have ordered, or otherwise directed, the arrest or prosecution of certain persons in Venezuela. The Executive Order set forth standards for designating and suspending entry into the United States of corresponding persons in Venezuela. The regulations provide the framework for blocking property or interests in property of persons designated according to the Executive Order. According to OFAC, the regulations are currently in “abbreviated form” and the agency will issue a more comprehensive set of regulations that may provide further interpretive guidance, general licenses, and statements of licensing policy.

    Sanctions OFAC

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