The U.S. Treasury Department Office of Foreign Assets Control ("OFAC") sanctioned seven individuals and 23 entities in a corruption scheme designed to exploit Venezuela's currency exchange practices. A private aircraft was also identified as blocked property.
Pursuant to Executive Order 13850, OFAC targeted individuals, including two former Venezuelan National Treasurers, for a scheme that allegedly generated over $2.4 billion in corrupt proceeds since 2008. The illicit profits were invested in assets including aircraft, yachts, horses and watches.
As a result of OFAC's action, all properties and interests in property of those designated as subject to U.S. jurisdiction are blocked, and U.S. persons generally are barred from participating in transactions involving these persons. With respect to two of those entities, Globovision Tele C.A. and Globovision Tele CA, Corp., OFAC issued a general license that authorizes certain transactions and activities for a one-year period. OFAC provided an FAQ to explain General License 6.
Commentary / James Treanor
General License 6 finds its precedent in similar authorizations issued in the context of OFAC's Ukraine-related sanctions program. Those authorizations were kept in effect for over eight months while OFAC worked out a deal for Oleg Deripaska (the primary target of its sanctions) to relinquish his majority ownership in certain sanctioned companies. OFAC notified Congress last month that a deal had been reached to "dis-entangle" the companies from Mr. Deripaska - including measures to ensure that Deripaska would not continue to exercise control over the companies - thus paving the way for OFAC's "delisting" of the sanctions entities. Treasury could not have been clearer that it seeks a similar outcome with respect to the Venezuela-based Globovision network, stating that "[t]he path for the United States to provide permanent sanctions relief to these entities is through divestment and relinquishment of control by any Specially Designated Nationals, including Gorrin and Perdomo."
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