Venezuela is added to The OFAC Sanctions List
By: Avalon Risk Management
Published March 2015 Newsletter

The Office of Foreign Assets Control (OFAC) of the US Department of the Treasury has added Venezuela to their sanctions list joining 26 other programs.  President Obama issued sanctions via Executive Order on Monday, March 9, against seven Venezuelan government officials for their “erosion of human rights guarantees” and public corruption.  The target of these sanctions included five current and former generals, a police official, and a prosecutor:

  • Antonio José Benavides Torres, Commander in Venezuela’s Bolivarian National Armed Forces
  • Gustavo Enrique González López, Director General of Venezuela’s Bolivarian National
  • Intelligence Service
  • Justo José Noguera Pietri, President of the Venezuelan Corporation of Guayana a state-owned entity
  • Manuel Eduardo Pérez Urdaneta, Director of Venezuela’s Bolivarian National Police
  • Manuel Gregorio Bernal Martínez, Chief of the 31st Armored Brigade of Caracas of Venezuela’s Bolivarian Army
  • Miguel Alcides Vivas Landino, Inspector General of Venezuela’s Bolivarian National Armed Forces
  • Katherine Nayarith Haringhton Padrón, National level prosecutor

Several more Venezuelan officials were recently added to OFAC’s Specially Designated Nationals (SDN) list.  According to the Executive Order, the U.S. is prohibited from doing business with these individuals. Along with having their U.S. assets and property blocked and frozen, the sanctioned officials are not permitted to travel to the U.S.

Relations between the two countries have adversely affected trade.  According to the United States Census Bureau in 2014, international trade between the U.S. and Venezuela was over 41 billion dollars; 11 billion in exports, and 30 billion in imports. This continued a downward trend in trading with Venezuela that began in 2011. Imports in January of 2015 were down almost 50 percent from what they were the year before.  The sanctions on these individuals could further influence the overall picture of trade between Venezuela and the U.S.

Avalon encourages you to take special precautions when dealing with OFAC sanctioned countries to avoid any E&O exposures or costly export violations.  We understand that trading with companies within sanctioned countries carries the increased risk of claims and legal matters. Government imposed fees and fines can be crippling especially when added to the cost of legal expenses.  Expanded Regulatory Defense coverage can assist with the legal expense required to defend your company.



 

For Venezuela and other OFAC countries, it is important to obtain full shipper and consignee to ensure proper screening for handling the shipment as well as insuring during transit with ocean marine insurance since special quotes are often required.  It is also a best practice to use an automated denied persons screening software to identify OFAC sanctioned programs and denied parties. The following is a list of OFAC sanctioned countries as of March 11, 2015, which is frequently subject to change and an automated software that monitors these changes can help you and your clients stay in compliance.

OFAC Sanctions Programs
Programs
Program Last Updated
02/07/14
08/11/11
10/31/14
07/07/14
01/06/11
02/24/15
02/26/15
01/15/15
07/08/14
12/30/14
05/27/14
07/30/10
04/02/13
09/11/14
12/29/14
03/06/15
01/02/15
05/21/08
07/05/12
02/17/15
09/18/14
12/17/14
07/02/14
03/11/15
03/06/15
11/10/14
7/10/14

Source: U.S. Census Bureau, OFAC

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