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OFAC designates Banco Central de Venezuela

  • USA
  • United Kingdom
  • Financial services disputes and investigations
  • Fraud and financial crime

26-04-2019

On 17 April 2019, The Office of Foreign Assets Control (OFAC) took steps to prevent the Banco Central de Venezuela, the Central Bank of Venezuela, from “being used as a tool of the illegitimate Maduro regime, which continues to plunder Venezuelan assets and exploit government institutions to enrich corrupt insiders”. [1]

These steps included designation of both the Central Bank of Venezuela, pursuant to Executive Order (“E.O.”) 13850, as amended by E.O. 13857, for operating in the financial sector of the Venezuelan economy, and Iliana Josefa Ruzza Terán, one of the bank’s directors, pursuant to E.O. 13692, as amended, for being a current or former official of the Government of Venezuela.

As discussed in previous briefings, there are a number of E.O.s currently in force against Venezuela, with U.S. sanctions against the country having steadily increased since March 2015 in response to the alleged abuse of human rights by the Venezuelan Government, specifically in their treatment of anti-government protestors.

The U.S. has targeted the Central Bank of Venezuela, based in Caracas, and Mr Terán, a Director of the bank, as a key entity and individual, respectively, in Venezuela’s financial sector in order to assist with preventing the Maduro regime from gaining access to the U.S. financial system.  Mr Terán is the latest in a line of individuals holding leadership positions with the bank who are subject to OFAC designations[2].  He is also a Director for the Venezuelan Department of Foreign Commerce and Vice President of Finance of Petroleos de Venezuela, S.A., which was designated on 28 January 2019, pursuant to E.O. 13850.

As a result of these designations, all property and interests in property of the Central Bank of Venezuela or Mr Terán, and any entity that is owned, directly or indirectly, 50 percent or more by the Central Bank of Venezuela and Mr Terán, that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. 

The U.S. has, however, reaffirmed its commitment to helping the people of Venezuela and has taken steps to ensure that:

  • regular debit and credit card transactions can proceed; and
  • non-commercial, personal remittances and humanitarian assistance can continue and can reach those “suffering under the Maduro regime’s repression”[3]

To reflect the above commitment, general licenses have been issued (License 19 and 20) and amended (Licenses 3D, 4A, 9C, 15 and 16) for “non-commercial, personal remittances and provision of humanitarian assistance”[4]. A Venezuela-related FAQ has also been published.[5]

[1]  U.S. Department Press Release.

[2]  Simon Alejandro Zerpa Delgado and William Antonio Contreras, both of whom are Directors of the bank, were designated by OFAC pursuant to E.O. 13692 in 2017 and 2018, respectively.

[3]  As per Treasury Secretary Steven T.  Mnuchin.

[4]  As per Treasury Secretary Steven T.  Mnuchin.

[5]  https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_other.aspx#665


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