In November, President Trump issued an executive order taking further aim at purported corruption within the Government of Venezuela. Although the EO itself did not designate any entities or individuals, OFAC subsequently added a number of individuals and entities to the SDN list.
Executive Order 13850 ("Blocking Property of Additional Persons Contributing to the Situation in Venezuela"), issued on November 1, 2018, imposes blocking sanctions aimed at preventing the Maduro regime's efforts to exploit Venezuela's people and resources. Section 1 of EO 13850 imposes blocking sanctions on persons operating in the gold sector of the Venezuelan economy or involved in deceptive or corrupt conduct with respect to the Government of Venezuela or its programs. The executive order also imposes blocking sanctions on entities owned or controlled by blocked persons, or those who assist or act on behalf of persons blocked under the new Order. OFAC clarified that any sanctions issued pursuant to EO 13850 would be limited to those operating corruptly in the gold sector and other identified sectors of Venezuela's economy. Legitimate actors within those sectors will not be targeted.
On January 8, OFAC exercised its authority under EO 13850 for the first time by designating seven individuals and 23 entities allegedly involved in an expansive scheme to exploit the Government of Venezuela's currency exchange practices. According to OFAC, Venezuelan television mogul Raul Antonio Gorrin Belisario ("Gorrin") bribed the Venezuelan Treasury to grant approval to multiple brokerage firms controlled by Gorrin. Gorrin and his collaborators then used the brokerage firms to conduct favorable foreign exchange transactions. The $2.4 billion in corrupt profits were then invested in domestic and international assets, the ownership of which were disguised using as network of corporate entities and deceptive structures. The following individuals and companies were designated:
- Raul Gorrin Belisario
- Claudia Patricia Diaz Guillen
- Adrian Jose Velasquez Figueroa
- Leonardo Gonzalez Dellan
- Gustavo Adolfo Perdomo Rosales
- Maria Alexandra Perdomo Rosales
- Mayela Antonina Tarascio-Perez
- Globovision Tele C.A.
- Globovision Tele CA, Corp.
- Seguros La Vitalicia
- Corpomedios GV Inversiones, C.A.
- Corpomedios LLC
- RIM Group Investments, Corp.
- RIM Group Investments I Corp.
- RIM Group Investments II Corp.
- RIM Group Investments III Corp.
- RIM Group Properties of New York, Corp.
- RIM Group Properties of New York II Corp.
- Magus Holdings USA, Corp.
- Magus Holding LLC
- Magus Holding II LLC
- Tindaya Properties Holding USA Corp.
- Tindaya Properties of New York, Corp.
- Tindaya Properties of New York II Corp.
- Posh 8 Dynamic Inc.
- Constello No. 1 Corporation
- Constello Inc.
- Windham Commercial Group Inc.
- Planet 2 Reaching Inc.
- Potrico Corp.
- N133JA
Notably, OFAC immediately issued a general license (GL 6) permitting a 12-month period during which time persons may continue to maintain or wind-down pre-existing business involving Globovision Tele C.A. or Globovision Tele CA, Corp, or their subsidiaries. As with simliar licenses extended pursuant to Ukraine/Russia programs, OFAC emphasized that the "maintenance" of business would only be interpreted to include transactions "ordinarily incident to the continuity of operations" vi-a-vis the sanctioned targets, but noted that new or renewed contracts are permissible so long as they are consistent with past practices prior to January 8, 2019.
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