CLAP Food Distribution Program Sanctions

In July, 2019, the Office of Foreign Asset Control (OFAC) designated various persons and entities involved in theft and corruption in relation to Venezuela’s CLAP or food distribution program. Alex Nain Saab Moran led a network of corrupt businesspersons to bribe Nicholas Maduro’s regime and profit from bloated contracts with Los Comites Locales de Abastecimiento y Produccion (CLAP).

OFAC-Designated Individuals

The individuals designated today include:

  • Alex Saab
  • Alvaro Pulido
  • Emmanuel Rubio
  • Walter Flores
  • Yosser Flores
  • Yoswal Flores
  • Jose Mora
  • Shadi Certain
  • Isham Certain
  • Mariana Lemoine

Alex Nain Saab Moran led a network of corrupt businesspersons to bribe Nicholas Maduro’s regime and profit from bloated contracts with Los Comites Locales de Abastecimiento y Produccion (CLAP). Mr. Saab and his network also had dealings with Venezuela’s gold sector.

OFAC states that the stepsons of Nicolas Maduro – Walter, Yosser, and Yoswal, and their cousin, Carlos Malpica – form a network of individuals who profited from the scarcity of food in Venezuela by various means of storing, assembling, and shipping food products to avoid taxes and increase the price of products needed to feed the Venezuelan people.

Designated Entities

The entities designated today include:

  • Asasi Food Fzc
  • UAE Group Grand Limited, a Hong Kong entity
  • Group Grand Limited, a Mexican entity
  • Mulberry, a U.S.-Turkish entity owned by Alex Saab
  • Seafire Foundation, a Panamanian entity
  • CI Fondo Global de Alimentos LTDA, a Columbian entity
  • EMMR & CIA S.A.S., a Colombian entity
  • Global Structure S.A., a Panamanian entity
  • Multitex International Trading S.A., a Panamanian entity
  • Sun Properties LLC, an entity registered in Delaware
  • CLIO Management Corporation, a Panamanian entity
  • Silver Bay Partners FZE, a UAE entity

Due to these sanctions, U.S. persons are not permitted to engage in dealings with these persons and entities without prior authorization. All entities that are 50% owned or more by these persons and entities are also blocked if they come within U.S. jurisdiction. International entities in South America, Central America and in the Middle East should be aware that any significant dealings with these entities may result in designation on the OFAC sanctions or SDN list.

Consult with a DC OFAC Attorney

Sanctions compliance attorneys keep up to date on further updates to the SDN list, and individuals with questions or concerns should contact an attorney for help. Experienced OFAC lawyers can help navigate the complex regulations involved with sanctions compliance