ARTICLE
8 October 2019

OFAC Sanctions Individuals Involved In Corruption Of Venezuela's Food Subsidy Program

CW
Cadwalader, Wickersham & Taft LLP

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OFAC designated three individuals and 16 entities in connection with a "large-scale network of corruption" related to a Venezuelan
United States Criminal Law

OFAC designated three individuals and 16 entities in connection with a "large-scale network of corruption" related to a Venezuelan food subsidy and distribution program.

OFAC found that the designated individuals are associated with, and the entities are controlled by, the designated Colombian national, Alex Saab. As previously covered, Mr. Saab created a network of front and shell companies that profited illicitly from involvement in Venezuela's food subsidy and other social programs. According to OFAC, the network of shell companies "laundered hundreds of millions of dollars in corruption proceeds around the world."

OFAC restated that "U.S. sanctions need not be permanent" and that "sanctions are intended to change behavior." In addition, OFAC stated that the U.S. would "consider lifting sanctions for persons designated under E.O. 13850, as amended, who take concrete and meaningful actions to restore democratic order, refuse to take part in human rights abuses, speak out against abuses committed by the Government of Venezuela, and combat corruption in Venezuela."

All property and interests in property of these individuals, as well as any entities that are 50 percent or more owned by them, that are in the United States or are in the possession or control of U.S. persons, are now blocked and must be reported to OFAC. Additionally, OFAC regulations generally prohibit any dealings by U.S. persons, or within the United States, that involve these individuals, their property or interests in property.

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