ARTICLE
3 May 2019

OFAC Targets Venezuelan And Nicaraguan Regimes

CW
Cadwalader, Wickersham & Taft LLP

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In concurrent actions, OFAC sanctioned the Central Bank of Venezuela and its director
United States International Law

In concurrent actions, OFAC sanctioned the Central Bank of Venezuela and its director, as well as the son of Nicaraguan President Daniel Ortega and a Nicaraguan bank owned by Venezuela's state-owned oil company, Petróleos de Venezuela, S.A. ("PdVSA").

Pursuant to Executive Order 13850, OFAC designated the Central Bank of Venezuela. According to Treasury Secretary Steven T. Mnuchin, the move was designed "to prevent [the bank] from being used as a tool of the illegitimate Maduro regime." OFAC also designated Central Bank of Venezuela Director Iliana Josefa Ruzza Terán, pursuant to Executive Order 13692.

OFAC also issued two new, and five amended, General Licenses pertaining to financial transactions involving Venezuelan entities, including the country's Central Bank. As explained in an FAQ, the authorizations contained in the General Licenses are intended to, among other things, permit U.S. persons and others to engage in or facilitate the provision of humanitarian assistance or non-commercial, personal remittances to Venezuela.

In addition, pursuant to Executive Order 13851, OFAC designated the son of Nicaraguan President Daniel Ortega, Laureano Ortega Murillo, and a Nicaraguan bank, Banco Corporativo SA ("BanCorp").

According to OFAC, Mr. Murillo and BanCorp support a regime whose actions have led to the deaths of over 300 individuals and created tens of thousands of refugees. Nicaraguan Vice President Rosario Murillo, who is the mother of Laureano Ortega Murillo and the wife of President Ortega, was previously designated by OFAC in November 2018.

U.S. Treasury Under Secretary Sigal Mandelker stated:

"The corrupt Ortega regime has ignored the Nicaraguan people's calls for reform, including the freeing of all political prisoners, and early transparent elections."

As a result of OFAC's actions, all property and interests in property of the designated persons, or of any entity that is owned by one or more designated persons, that are in the United States or are in the possession or control of U.S. persons, are blocked and must be reported to OFAC. OFAC's regulations generally forbid 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.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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