In March, The Office of Foreign Asset Control (OFAC) designated Venezuela’s Banco de Desarrollo Economico y Social de Venezuela (BANDES) for the arrest of an aide of Juan Guaido. They believe that BANDES was involved in arresting Roberto Marrero and other political prisoners. The United States seeks to alter the activities of these financial institutions in their support of Maduro’s actions.

Details of the March 2019 BANDES Sanctions

BANDES is Venezuela’s National Development Bank. Other entities that were designated in this action include Banco Bandes, Uruguay SA, Banco Universal SA, Banco de Venezuela and Banco Prodem SA of Bolivia. This is a broad designation of various national banking and financial institutions partly-owned by the Venezuelan government, it will affect certain financial transactions occurring in US dollars, particularly those with State Bank of Venezuela and international counterparts.

There are also five corresponding general licenses, 15 through 18, which were published today. General licenses authorize a specific scope of transactions in relation to the recent Venezuelan designations. is going to be important for anyone who has any form of present or future transactions with these banks to take note of the general license to see what exactly is broadly authorized and what is not based on the recent designations of these Venezuelan banks.

Impact of the New Sanctions

These sanctions may affect US importers of Venezuelan petroleum or anyone doing business in South America whose transactions involve he designated banks. Individuals and entities who violate these sanctions risk their funds being blocked by financial institutions. It will be important for companies internationally to review their involvement with the designated entities and ensure their transactions do not violate US sanctions. Additionally, U.S. businesses and individuals should review the general licenses to see what exactly is broadly authorized and what is not based on the recent designations.

For help reviewing transactions for sanctions compliance, reach out to an experienced DC OFAC sanctions attorney.