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Get ‘em while they’re hot: changes in counter terrorism, Venezuela, CAATSA-Russia and Yemen sanctions programs.

Today, on January 19th, the U.S. Department of State designated Ansarallah as a Foreign Terrorist Organization under section 219 of the Immigration and Nationality Act, as amended, and as a Specially Designated Global Terrorist under Executive Order (E.O.) 13224, as amended and have been added to the Specially Designated Nationals and Blocked Person List.  Additionally, the U.S. Department of State also designated three of Ansarallah’s leaders as Specially Designated Global Terrorists pursuant to E.O. 13224, as amended.  The United States is committed to supporting the provision of humanitarian assistance to the Yemeni people.  Concurrent with the designations, OFAC issued four General Licenses—General License 9, “Official Business of the United States Government,” General License 10, “Official Activities of Certain International Organizations, General License 11, “Certain Transactions in Support of Nongovernmental Organizations’ Activities in Yemen,” and General License 12, “Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components or Software Updates”—and three Frequently Asked Questions (875, 876, 877), to help facilitate the uninterrupted flow of humanitarian assistance, including COVID-19-related assistance, and certain other critical commodities to the people of Yemen that would otherwise be prohibited pursuant to authorities administered by OFAC. 

And OFAC added the following persons:

APIKIAN, Philipp Paul Vartan; DOB 15 Jan 1969; POB Geneva, Switzerland; citizen Switzerland; Gender Male; Passport X0062329 (Switzerland) issued 27 Feb 2012 expires 26 Feb 2022 (individual) [VENEZUELA-EO13850]. 
 
BAZZONI, Alessandro, Via Cantonale 8, Lugano 6900, Switzerland; DOB 09 Jul 1971; POB Milan, Italy; citizen Italy; Gender Male; Passport YA9636063 (Italy) issued 12 Jul 2016 expires 11 Jul 2026 (individual) [VENEZUELA-EO13850]. 
 
D’AGOSTINO CASADO, Francisco Javier, Calle El Parque. Res. Campo Alegre Plaza, Piso 5. Urb. Campo Alegre, Caracas, Miranda 1060, Venezuela; DOB 02 Jun 1974; POB Caracas, Venezuela; nationality Spain; citizen Spain; alt. citizen Venezuela; Gender Male; Cedula No. V-11307398 (Venezuela); Passport XDC221294 (Spain) issued 18 Sep 2015 expires 11 Jul 2018; National ID No. R.E. 201000798316 (Spain) (individual) [VENEZUELA-EO13850]. 

and entities:

82 ELM REALTY LLC, 450 Park Avenue, Ste 1403, New York, NY 10022, United States; Company Number 3848561 (New York) (United States) [VENEZUELA-EO13850]. 
 
AMG S.A.S. DI ALESSANDRO BAZZONI & C. (a.k.a. AMG S.A.S. DI ALESSANDRO BAZZONI AND C.; a.k.a. AMG S.A.S. DI ALESSANDRO BAZZONI E C.), Via Sottomonte 5, Verona 37124, Italy; V.A.T. Number IT02483560237 (Italy) [VENEZUELA-EO13850]. 
 
CATALINA HOLDINGS CORP., New York, NY 10107-1706, United States; Company Number 3934472 (New York) (United States) [VENEZUELA-EO13850]. 
 
D’AGOSTINO & COMPANY, LTD (a.k.a. D’AGOSTINO AND COMPANY, LTD), Torre Dayco, Piso PH, Caracas, Venezuela; Organization Type: Other financial service activities, except insurance and pension funding activities, n.e.c. [VENEZUELA-EO13850]. 
 
ELEMENT CAPITAL ADVISORS LIMITED, Avenida Federico Boyd con Calle 49, Edificio Alfaro Piso 4 Oficina 4-A, Apartado 0832-00998, Panama City, Panama; Virgin Islands, British; Website http://www.element-capital.com; Nationality of Registration Virgin Islands, British; Organization Type: Other financial service activities, except insurance and pension funding activities, n.e.c.; Company Number 1476279 (Virgin Islands, British) [VENEZUELA-EO13850]. 
 
ELEMENTO LIMITED, 35 Strait Street, Valletta VLT 1434, Malta; 85 St. John Street, Valletta MT-VLT1165, Malta; Norway; Website http://www.elemento.com.mt; Company Number C 72520 (Malta); alt. Company Number 920167667 (Norway) [VENEZUELA-EO13850]. 
 
ELEMENTO OIL & GAS LTD (a.k.a. ELEMENTO OIL AND GAS LTD), 35 Strait Street, Valletta VLT 1434, Malta; Company Number C 73377 (Malta) [VENEZUELA-EO13850]. 
 
ELEMENTO SOLUTIONS LIMITED, 12 Hay Hill, London W1J 8NR, United Kingdom; Company Number 10289741 (United Kingdom) [VENEZUELA-EO13850]. 
 
FIDES SHIP MANAGEMENT LLC (a.k.a. TOVARYSTVO Z OBMEZHENOYU VIDPOVIDALNISTYU FIDES SHYP MENEDZHMENT), Bud.42,VUL.MARSELSKA Suvorovsky R-N, Odessa 65123, Ukraine; Organization Established Date 01 Jan 2015 to 31 Dec 2015; Organization Type: Activities of holding companies; alt. Organization Type: Sea and coastal freight water transport [VENEZUELA-EO13850]. 
 
INSTITUTO NACIONAL DE LOS ESPACIOS ACUATICOS E INSULARES (a.k.a. “INEA”), Av. Orinoco, Edificio I.N.E.A., Caracas, Venezuela; Identification Number IMO 4166811 [VENEZUELA-EO13850]. 
 
JAMBANYANI SAFARIS, 364 Gibson Road, Victoria Falls, Zimbabwe; P.O. Box 155, Victoria Falls, Zimbabwe; Website http://www.jambanyani.com; Organization Established Date 28 Sep 2019; Organization Type: Tour operator activities [VENEZUELA-EO13850]. 
 
RUSTANKER LLC, ul Lenina 32, Temryuk, Krasnodarskiy Kray 353500, Russia; Identification Number IMO 6166689 [VENEZUELA-EO13850]. 
 
SERIGRAPHICLAB DI BAZZONI ALESSANDRO, Via Amsicora 46, Porto Torres 07046, Italy; V.A.T. Number 02732450909 (Italy) [VENEZUELA-EO13850]. 
 
SWISSOIL TRADING SA, Rue Pierre-Fatio 15, Geneva 1204, Switzerland; Website https://www.swissoil.trading/; V.A.T. Number CHE-104.851.121 (Switzerland) [VENEZUELA-EO13850]. 

and vessels:

BALIAR Crude/Oil Products Tanker Liberia flag; Vessel Registration Identification IMO 9192258 (vessel) [VENEZUELA-EO13850] (Linked To: FIDES SHIP MANAGEMENT LLC). 
 
BALITA (f.k.a. ANGLIA) Crude/Oil Products Tanker Cameroon flag; Vessel Registration Identification IMO 9176773 (vessel) [VENEZUELA-EO13850] (Linked To: FIDES SHIP MANAGEMENT LLC). 
 
DOMANI (f.k.a. GERD KNUTSEN) Shuttle Tanker Cameroon flag; Vessel Registration Identification IMO 9041057 (vessel) [VENEZUELA-EO13850] (Linked To: FIDES SHIP MANAGEMENT LLC). 
 
FREEDOM (f.k.a. MAGUS) Crude Oil Tanker Cameroon flag; Vessel Registration Identification IMO 9018464 (vessel) [VENEZUELA-EO13850] (Linked To: FIDES SHIP MANAGEMENT LLC). 
 
MAKSIM GORKY (f.k.a. MAXIMO GORKI) Crude Oil Tanker Russia flag; Vessel Registration Identification IMO 9590008 (vessel) [VENEZUELA-EO13850] (Linked To: INSTITUTO NACIONAL DE LOS ESPACIOS ACUATICOS E INSULARES). 
 
SIERRA (f.k.a. SIENNA) Crude/Oil Products Tanker Russia flag; Vessel Registration Identification IMO 9147447 (vessel) [VENEZUELA-EO13850] (Linked To: RUSTANKER LLC). 

under the Venezuela sanctions program, the following entity:

ANSARALLAH (a.k.a. ANSAR ALLAH; a.k.a. “ANSARULLAH”; a.k.a. “PARTISANS OF GOD”; a.k.a. “SUPPORTERS OF GOD”), Yemen; Additional Sanctions Information – Subject to Secondary Sanctions [FTO] [SDGT]. 

under the counter terrorism sanctions program, and the following entity:

KVT-RUS (Cyrillic: КВТ-РУС) (a.k.a. KBT-RUS; a.k.a. KVT-RUS, OOO (Cyrillic: ООО, КВТ-РУС); a.k.a. LIMITED LIABILITY COMPANY KVT-RUS (Cyrillic: ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ КВТ-РУС)), 6,2 Pudovkina St., Moscow 119285, Russia; CAATSA Section 235 Information: EXPORT SANCTIONS Sec. 235(a)(2); alt. CAATSA Section 235 Information: FOREIGN EXCHANGE. Sec 235(a)(7); alt. CAATSA Section 235 Information: BANKING TRANSACTIONS. Sec 235(a)(8); alt. CAATSA Section 235 Information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY. Sec 235(a)(9); alt. CAATSA Section 235 Information: BAN ON INVESTMENT IN EQUITY OR DEBT OF SANCTIONED PERSON. Sec 235(a)(10); Tax ID No. 7729675572 (Russia); Business Registration Number 1117746121899 (Russia) [CAATSA – RUSSIA]. 

and vessel:

FORTUNA (UBDP8) Russia flag; Vessel Registration Identification IMO 8674156 (vessel) [CAATSA – RUSSIA]. 

under the CAATSA-Russia program.

Additionally, the following existing Yemen program designations were updated to add them to the counter terror program:

AL HAKIM, Abdullah Yahya (a.k.a. AL HAKIM, Abu Ali; a.k.a. AL-HAKIM, Abdallah; a.k.a. ALHAKIM, Abu Ali; a.k.a. AL-HAKIM, Abu-Ali; a.k.a. AL-MU’AYYAD, Abdallah), Dahyan, Sa’dah Governorate, Yemen; DOB 1985; alt. DOB 1984 to 1986; POB Dahyan, Yemen; alt. POB Sa’dah Governorate, Yemen; nationality Yemen; Gender Male; Huthi group second-in-command (individual) [YEMEN]. -to- AL HAKIM, Abdullah Yahya (a.k.a. AL HAKIM, Abu Ali; a.k.a. AL-HAKIM, Abdallah; a.k.a. ALHAKIM, Abu Ali; a.k.a. AL-HAKIM, Abu-Ali; a.k.a. AL-MU’AYYAD, Abdallah), Dahyan, Sa’dah Governorate, Yemen; DOB 1985; alt. DOB 1984 to 1986; POB Dahyan, Yemen; alt. POB Sa’dah Governorate, Yemen; nationality Yemen; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Ansarallah Chief of Military Intelligence Staff (individual) [SDGT] [YEMEN] (Linked To: ANSARALLAH). 
 
AL HOUTHI, Abdul Malik (a.k.a. AL-HOUTHI, Abdel-Malek; a.k.a. AL-HOUTHI, Abdel-Malik; a.k.a. AL-HOUTHI, Abdul Malik Badruddin Ameerudin Hussain; a.k.a. AL-HOUTHI, Abdul-Malik; a.k.a. AL-HOUTHI, Abdulmalik Bin Bader Al-Deen); DOB 1982; alt. DOB 1981; alt. DOB 1980; POB Dahyan Governorate, Yemen; nationality Yemen; Leader of the Houthi group (individual) [YEMEN]. -to- AL HOUTHI, Abdul Malik (a.k.a. AL-HOUTH, Abdulmalik Bin Bader Al-Deen; a.k.a. AL-HOUTHI, Abdel-Malek; a.k.a. AL-HOUTHI, Abdel-Malik; a.k.a. AL-HOUTHI, Abdul Malik Badruddin Ameerudin Hussain; a.k.a. AL-HOUTHI, Abdul-Malik; a.k.a. AL-HOUTHI, Abdulmalik Bin Bader Al-Deen); DOB 1982; alt. DOB 1981; alt. DOB 1980; POB Dahyan Governorate, Yemen; nationality Yemen; citizen Yemen; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Leader of Ansarallah (individual) [SDGT] [YEMEN] (Linked To: ANSARALLAH). 
 
AL-HUTHI, Abd al-Khaliq (a.k.a. ABU-YUNUS; a.k.a. AL HUTHI, Abd-al-Khaliq Badr-al-Din; a.k.a. AL-HUTHI, ‘Abd al-Khaliq Badr al-Din; a.k.a. AL-HUTHI, Abd-al-Khaliq); DOB 1984; Gender Male; Huthi military commander (individual) [YEMEN]. -to- AL-HUTHI, Abd al-Khaliq (a.k.a. ABU-YUNUS; a.k.a. AL HUTHI, Abd-al-Khaliq Badr-al-Din; a.k.a. AL-HOUTHI, Abd al-Khaliq; a.k.a. AL-HOUTHI, Abd al-Khaliq Badr al-Din; a.k.a. AL-HOUTHI, Abdul Khaliq Badreddin; a.k.a. AL-HUTHI, ‘Abd al-Khaliq Badr al-Din; a.k.a. AL-HUTHI, Abd al-Khaliq Badr al-Din; a.k.a. AL-HUTHI, Abd-al-Khaliq); DOB 1984; nationality Yemen; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Ansarallah military commander (individual) [SDGT] [YEMEN] (Linked To: ANSARALLAH). 

Here are the new FAQs:

875. Are U.S. persons prohibited from supporting humanitarian efforts in Yemen, including by engaging in or facilitating the provision of humanitarian assistance to Yemen, if those efforts involve Ansarallah?

Answer

Ansarallah was designated on January 19, 2021 as a Foreign Terrorist Organization under section 219 of the Immigration and Nationality Act, as amended, and as a Specially Designated Global Terrorist under Executive Order (E.O.) 13224, as amended.  These sanctions do not prohibit U.S. persons from exporting or reexporting goods or services to Yemen, provided that the transactions do not involve sanctioned individuals or entities, or property in which a blocked person has an interest unless exempt from regulation or authorized by OFAC.  

Concurrent with the designation of Ansarallah, OFAC issued four General Licenses (GLs) to facilitate the uninterrupted flow of humanitarian assistance and certain other critical commodities to the people of Yemen.  These GLs, issued under the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 C.F.R. part 597 (FTOSR), and E.O. 13224, as amended, authorize certain humanitarian and other activities that involve Ansarallah, or any entity in which Ansarallah owns, directly or indirectly, a 50 percent or greater interest, and that are prohibited by the GTSR, the FTOSR, or E.O. 13224.  Specifically, OFAC issued GL 12, which authorizes certain transactions related to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to Yemen, or to persons in third countries purchasing specifically for resale to Yemen.  OFAC also issued GL 11, which authorizes certain activities by nongovernmental organizations to support humanitarian projects, democracy building, education, non-commercial development projects, and environmental protection in Yemen.  GLs 11 and 12 also authorize all transactions and activities that are ordinarily incident and necessary to the activities authorized by these GLs, including but not limited to the processing and transfer of funds, payment of taxes, fees, and import duties, and purchase or receipt of permits, licenses, or public utility services.

Furthermore, OFAC issued GLs 9 and 10, respectively, to authorize the official activities of the U.S. government and certain international organizations, such as the United Nations and the International Committee of the Red Cross, to the extent the transactions are subject to U.S. jurisdiction.

In addition to these GLs, OFAC may also issue specific licenses to authorize certain transactions involving U.S. persons or the U.S. financial system that may otherwise be prohibited by OFAC sanctions, provided those transactions are in the foreign policy interests of the United States.  

If individuals, companies, or financial institutions have questions about engaging in or processing transactions related to these authorizations, they can contact OFAC’s Sanctions Compliance and Evaluation Division at (800) 540-6322 or (202) 622-2490.

876. Do non-U.S. persons risk exposure to sanctions under E.O. 13224, as amended, for engaging in transactions involving Ansarallah, or any entity in which Ansarallah owns a 50 percent or greater interest, that U.S. persons would be authorized to engage in under General Licenses 9, 10, 11, and 12?

Answer

Non-U.S. persons may engage in or facilitate transactions involving Ansarallah, or any entity in which Ansarallah owns, directly or indirectly, a 50 percent or greater interest, without exposure to sanctions under E.O. 13224, as amended, if such activity would be authorized under General Licenses (GLs) 9, 10, 11, and 12 if engaged in by a U.S. person.  Activity that would be authorized by GLs 9, 10, 11, and 12 if engaged in by a U.S. person would not be considered “significant” for the purposes of a secondary sanctions determination under E.O. 13224, as amended.  

Accordingly, foreign financial institutions do not risk exposure to correspondent and payable-through account sanctions under E.O. 13224, as amended, if they knowingly conduct or facilitate a transaction on behalf of Ansarallah, or any entity in which Ansarallah owns, a 50 percent or greater interest, that would be authorized under GLs 9, 10, 11, and 12 if engaged in by a U.S. person.

877. Can U.S. and non-U.S. persons provide humanitarian assistance in response to the Coronavirus Disease 2019 (COVID-19) outbreak in Yemen following the designation of Ansarallah?

Answer

Yes.  U.S. persons may continue to provide humanitarian goods or assistance to the Yemeni people in response to the COVID-19 outbreak in Yemen, consistent with U.S. sanctions.  With respect to certain activities that may result in transactions with or that provide benefits to Ansarallah, or an entity in which Ansarallah owns a 50 percent or greater interest, OFAC issued General Licenses (GLs) 9, 10, 11, and 12 under the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 C.F.R. part 597 (FTOSR), and Executive Order (E.O.) 13224, as amended, authorizing the provision of certain goods and assistance by the U.S. government, international organizations, non-governmental organizations, and individuals and entities delivering food, medicine, medical supplies, and humanitarian assistance to Yemen.  

Pursuant to GL 12, U.S. persons may engage in all transactions and activities that are ordinarily incident and necessary to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to Yemen, or to persons in third countries purchasing specifically for resale to Yemen that involve the Ansarallah, or any entity in which Ansarallah owns a 50 percent or greater interest, subject to certain conditions.  GL 12’s authorizations extend to the exportation or reexportation of items that may be used in the fight against COVID-19, including personal protective equipment and other items such as medical gowns, medical eye shields and goggles, surgical gloves, face shields, respirators and masks such as N95, N99, and N100 masks, oxygen generators, full face mask respirators including Powered Air Purifying Respirators, diagnostic medical imaging equipment, decontamination equipment, and ventilators.

For more information on what GLs 9, 10, 11, and 12 authorize, and non-U.S. persons’ exposure to sanctions for engaging in activity authorized by GLs 9, 10, 11, and 12, see FAQs 875 and 876.

And the State Department issued the following press release on the Venezuela designations:

The United States has sanctioned three individuals and 11 entities for their ties to a network helping Nicolas Maduro and his illegitimate regime evade U.S. sanctions on Venezuela’s oil sector.  This action builds on previous sanctions targeting individuals and entities involved in a sanctions-evasion scheme benefitting the illegitimate Maduro regime and Petroleos de Venezuela, S.A. (PdVSA), which the regime uses as its primary conduit for corruption to exploit and profit from Venezuela’s natural resources.  The principal actors in the evasion network include Alessandro Bazzoni, Francisco Javier D’Agostino Casado, Philipp Paul Vartan Apikian, Elemento Ltd, and Swissoil Trading SA.

Additionally, OFAC is designating three companies located in Russia, Ukraine, and Venezuela, and identifying as blocked property six vessels that have recently been involved in the lifting and transport of Venezuelan oil.  This action aims to increase pressure on international shipping entities to disengage from the Venezuelan oil sector and further limit the illegitimate Maduro regime’s options for selling oil.

Those facilitating Maduro’s attempts to circumvent U.S. sanctions enable him to continue his repressive practices against the Venezuelan people while pillaging Venezuela’s resources to enrich himself and his cronies.  The United States remains committed to promoting accountability for those involved in facilitating illegitimate transactions that benefit Maduro and his corrupt network while contributing to the suffering of the Venezuelan people.  We will continue to use the full weight of U.S. economic and diplomatic power to promote the peaceful transition to a once-again free, prosperous, and stable Venezuela.

and one on the CAATSA-Russia designations:

Today, the United States is imposing sanctions on the Russia-based entity KVT-RUS and identifying the vessel FORTUNA as blocked property.  KVT-RUS is being sanctioned pursuant to Section 232 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) for knowingly selling, leasing, or providing to the Russian Federation goods, services, technology, information, or support for the construction of Russian energy export pipelines.  The United States will consider further actions in the near term, under CAATSA, and the Protecting European Energy Security Act (PEESA), as amended.

Nord Stream 2, if completed, would give Russia the means to completely bypass Ukraine, depriving Ukraine of vital revenues and opening it up to further Russian aggressive actions, while providing the means to use natural resources as a tool of political pressure and malign influence against western Europe.  Today’s announcement demonstrates that the United States is not afraid to hold accountable those who continue to aid and abet this tool of Russian coercion.

The United States will continue to work with our friends and allies to ensure Europe has a reliable, diversified energy supply network that does not undermine collective security.

And the Treasury Department issued a press release on the Venezuelan action:

PRESS RELEASES

Treasury Targets Venezuelan Oil Sector Sanctions Evasion Network

Washington – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated three individuals, fourteen entities, and six vessels for their ties to a network attempting to evade United States sanctions on Venezuela’s oil sector. The illegitimate Maduro regime has continued to use Petroleos de Venezuela, S.A. (PdVSA) as its primary conduit for corruption to exploit and profit from Venezuela’s natural resources. Today’s action, taken pursuant to Executive Order 13850, as amended, builds on OFAC’s June 18, 2020 designations targeting Libre Abordo, S.A. de C.V. (Libre Abordo) and a wider Mexico-based network involved in the illicit sale of Venezuelan oil. Today’s action targets additional orchestrators and facilitators with ties to the Mexico network who have conspired with Maduro’s oil minister, Tareck El Aissami Maddah (El Aissami), and indicted money launderer Alex Nain Saab Moran (Saab) to broker the sale of hundreds of millions of dollars of Venezuelan oil.

“Those facilitating the illegitimate Maduro regime’s attempts to circumvent United States sanctions contribute to the corruption that consumes Venezuela,” said Secretary Steven T. Mnuchin. “The United States remains committed to targeting those enabling the Maduro regime’s abuse of Venezuela’s natural resources.”

The principal actors designated today include Alessandro Bazzoni (Bazzoni), Francisco Javier D’Agostino Casado (D’Agostino), Philipp Paul Vartan Apikian (Apikian), Elemento Ltd (Elemento), and Swissoil Trading SA (Swissoil).

CONTINUATION OF SANCTIONS EVASION NETWORK

On June 18, 2020, OFAC designated Joaquin Leal Jimenez (Leal), Olga Maria Zepeda Esparza (Zepeda), Veronica Esparza Garcia (Esparza), Libre Abordo, and Schlager Business Group S. de R.L. de C.V. (Schlager Business Group) for operating a sanctions-evasion scheme benefitting the illegitimate Maduro regime and PdVSA. The illegitimate Maduro regime, PdVSA, and Saab enlisted Libre Abordo and Leal in a scheme designed to evade U.S. sanctions in which Leal served as the conduit between the Mexico-based network and Saab, D’Agostino, and Bazzoni.

Elemento is based in Valletta, Malta, and has operated in the global oil sector since at least 2017. Elemento has purchased oil from PdVSA and then resold it to third-party customers on behalf of Bazzoni. Between July 2019 and July 2020, Elemento lifted and brokered the sale of at least five shipments of Venezuelan-origin crude oil supplied by PdVSA, several of which were coordinated directly with Libre Abordo or Swissoil. Elemento was designated today for operating in the oil sector of the Venezuelan economy and because it has materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, PdVSA.

Swissoil, based in Geneva, Switzerland, participated in the scheme by assisting in the sale and shipping of Venezuelan-origin crude oil to buyers in Asia. Swissoil often acted as the consignee, or the entity financially responsible for the receipt of a shipment, for oil shipments brokered by Elemento. Swissoil was also the recipient of at least one shipment of Venezuelan oil in Asia. Swissoil was designated today for operating in the oil sector of the Venezuelan economy and because it has materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, PdVSA.

D’Agostino, a dual Spanish-Venezuelan citizen, worked with Saab, Leal, and Bazzoni to coordinate the purchase and sale of Venezuelan-origin crude oil on behalf of PdVSA. D’Agostino has been involved in the Venezuelan oil sector since at least 2012 and has partnered with Bazzoni and others on multiple business ventures with PdVSA. D’Agostino has been implicated in a number of projects in the Venezuelan oil sector. D’Agostino was designated today for operating in the oil sector of the Venezuelan economy and because he has materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, PdVSA.

Bazzoni, along with D’Agostino, is a core facilitator of the network, connecting Elemento and Swissoil with PdVSA and Saab. Bazzoni, an Italian citizen, has been instrumental in coordinating the purchase and sale of Venezuelan-origin crude oil from PdVSA. Following Saab’s June 2020 arrest in Cape Verde and OFAC’s designation of Leal, Bazzoni took over the core coordinating role in the ongoing scheme to broker the re-sale of Venezuelan-origin crude oil from PdVSA and charter vessels willing to go to Venezuela to load oil. Bazzoni was designated today for operating in the oil sector of the Venezuelan economy and because he has materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, PdVSA.

Apikian, a Swiss national, is the owner and director of Swissoil, and has been involved in the sale and shipment of Venezuela-origin crude oil. Apikian was designated today for having acted or purported to act for or on behalf of, directly or indirectly, Swissoil.

ENTITIES DESIGNATED FOR BEING OWNED OR CONTROLLED BY BLOCKED PERSONS

Also designated today are nine entities owned or controlled by Bazzoni, D’Agostino, or Elemento:

  • Elemento Oil and Gas Ltd (Elemento Oil) is a Malta-based entity incorporated in March 2015. Bazzoni is the sole shareholder of Elemento Oil. Elemento Oil was designated for being owned or controlled by Bazzoni.
  • Elemento Solutions Limited is an entity incorporated in the United Kingdom. Elemento Solutions Limited was designated for being owned or controlled by Elemento.
  • Element Capital Advisors Ltd is a Panama-based entity incorporated in the British Virgin Islands and was designated for being owned or controlled by D’Agostino.
  • AMG S.A.S. di Alessandro Bazzoni & C. (AMG) is an entity incorporated in Italy. AMG was designated for being owned or controlled by Bazzoni.
  • Serigraphiclab di Bazzoni Alessandro (Serigraphiclab) is an Italian entity incorporated as a sole proprietorship owned by Alessandro Bazzoni. Serigraphiclab was designated for being owned or controlled by Bazzoni.
  • Jambanyani Safaris is a Zimbabwe-based entity and was designated for being owned or controlled by D’Agostino.
  • D’Agostino & Company, Ltd is an entity located in Venezuela. D’Agostino & Company, Ltd was designated for being owned or controlled by D’Agostino.
  • Catalina Holdings Corp. (Catalina) is an entity incorporated in New York and was designated for being owned or controlled by D’Agostino.
  • 82 Elm Realty LLC (82 Elm) is a New York limited liability company and was designated for being owned or controlled by D’Agostino.

VESSELS

Today’s action also includes the designation and blocking of the following maritime entities and vessels. The entities were designated for operating in the oil sector of the Venezuelan economy, and the vessels were identified as blocked property of these entities. All the vessels have recently lifted Venezuelan oil and thus have facilitated continued sanctions evasion and related activities for PdVSA and the illegitimate regime of Nicolas Maduro:

  • Fides Ship Management LLC is located in Odessa, Ukraine and manages or operates the following vessels:
    • Baliar is a Liberian-flagged crude oil tanker (IMO: 9192258).
    • Balita is a Cameroon-flagged crude oil tanker (IMO: 9176773).
    • Domani is a Cameroon-flagged shuttle tanker (IMO: 9041057).
    • Freedom is a Cameroon-flagged crude oil tanker (IMO: 9018464).
  • Instituto Nacional de los Espacios Acuaticos e Insulares (INEA) is located in Venezuela. INEA is the registered owner of the vessel Maksim Gorky.
    • Maksim Gorky is a Russian-flagged crude oil tanker (IMO: 9590008).
  • Rustanker LLC is located in Krasnodarskiy Kray, Russia and is the registered owner of the vessel Sierra.
    • Sierra is a Russian-flagged crude oil tanker (IMO: 9147447).

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of these individuals and 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. In addition, any entities that are owned, directly or indirectly, 50 percent or more by the designated individuals and entities, are also blocked. OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked or designated persons.

Links:

OFAC Notice

State Department Press Release (Venezuela)

State Department Press Release (CAATSA-Russia)

Treasury Department Press Release

Counter Terrorism General Licenses: 9, 10, 11, 12

Counter Terrorism FAQs: 875, 876, 877

Categories: CAATSA Sanctions Frequently Asked Questions (FAQ) Guidance Licenses OFAC Updates Russia sanctions Venezuela sanctions Yemen sanctions

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