Last Thursday, President Trump issued an Executive Order expanding sanctions on Venezuela. Here are the persons and organizations which can be designated under the new Executive Order:
(i) to operate in the gold sector of the Venezuelan economy or in any other sector of the Venezuelan economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State;
(ii) to be responsible for or complicit in, or to have directly or indirectly engaged in, any transaction or series of transactions involving deceptive practices or corruption and the Government of Venezuela or projects or programs administered by the Government of Venezuela, or to be an immediate adult family member of such a person;
(iii) to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any activity or transaction described in subsection (a)(ii) of this section, or any person whose property and interests in property are blocked pursuant to this order; or
(iv) to be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to this order.
In addition, OFAC added the following two new FAQs:
Executive Order “Blocking Property of Additional Persons Contributing to the Situation in Venezuela”
628. What is the objective of Executive Order (E.O.) of November 1, 2018, “Blocking Property of Additional Persons Contributing to the Situation in Venezuela”?
The E.O. is designed to counter rampant corruption within the Government of Venezuela, which continues to exacerbate the economic and humanitarian crises afflicting the Venezuelan people. As we have worked to disrupt the Government of Venezuela’s sources of corrupt patronage, the Maduro regime has sought new means by which to enrich itself at the expense of its people. By issuing this E.O., the U.S. government is acting to prevent the regime and its corrupt associates from further exploiting Venezuela’s people and resources. The E.O. provides a powerful tool to impose costs on those who unjustly benefit from dishonest or fraudulent conduct, illicit activity, and/or deceptive transactions within Venezuela’s gold sector or other identified sectors, or in relation to the Government of Venezuela or its projects or programs. [11-01-2018]
629. Executive order (E.O.) of November 1, 2018, “Blocking Property of Additional Persons Contributing to the Situation in Venezuela,” authorizes the imposition of sanctions on persons operating in Venezuela’s gold sector. For purposes of this E.O., how will OFAC target those who “operate in the gold sector of the Venezuela economy or any other sector of the Venezuela economy as may be determined by the Secretary of the Treasury in consultation with the Secretary of State”?
OFAC expects to use its discretion to target in particular those who operate corruptly in the gold or other identified sectors of the Venezuela economy, and not those who are operating legitimately in such sectors. This includes, for example, persons engaging in dishonest or fraudulent conduct, illicit activity, or deceptive transactions within Venezuela’s gold sector or other identified Venezuela sectors, with the purpose or effect of misappropriating Venezuelan resources in those sectors for personal, professional, or political gain. [11-01-2018]