On January 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced additions to the Specially Designated Nationals List pursuant to Executive Order 13850. OFAC’s additions to the list include seven individuals—including former Venezuelan government officials—and 23 entities for their participation in a bribery scheme involving the Venezuelan Office of the National Treasury in order to conduct illicit foreign exchange operations in the country. According to OFAC, the designated persons engaged in transactions involving deceptive practices and corruption, including wiring payments that were “hidden behind a sophisticated network of U.S. and foreign companies that hid the individuals’ beneficial ownership.” As a result, all assets belonging to the identified individuals and entities subject to U.S. jurisdiction are blocked, and U.S. persons generally are prohibited from dealing with them.

Concurrently, OFAC issued Venezuela-related General License 6 (GL 6) to allow U.S. persons to engage in otherwise prohibited wind-down transactions with two of the designated companies through January 8, 2020. Specifically, GL 6 authorizes certain activities with the designated companies relating to the maintenance and wind-down of operations, contracts, and agreements that were effective prior to January 8, 2019. OFAC also published a new FAQ to provide additional guidance on the types of activities considered “maintenance” under GL 6.

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