On July 31, OFAC designated Venezuelan President Nicolas Maduro as a Specially Designated National (SDN) under the Venezuela Sanctions Program, pursuant to Executive Order (E.O.) 13692.

Earlier, on July 26, OFAC added 13 other top Venezuelan officials to its SDN List. These newly designated individuals are linked with numerous branches and agencies of the Venezuelan government, including the ombudsman, the military and intelligence service, PDVSA (Venezuela’s state-owned oil and natural gas company), CENCOEX (Venezuela’s exchange controls agency), and the electoral council, among others. The individuals are:

1. Rocco Albissinni Serrano – President of CENCOEX.
2. Alejandro Fleming Cabrera – Ministry of Foreign Affairs and former President of CENCOEX.
3. Franklin Garcia Duque – Former National Director of Venezuela’s National Police.
4. Elias Jaua – Head of Venezuela’s Presidential Commission for the Constituent Assembly and Minister of Education.
5. Tibisay Lucena – President of Venezuela’s National Electoral Council.
6. Carlos Malpica Flores – Former National Treasurer of Venezuela and former Vice President of Finance for PDVSA.
7. Carlos Pérez Ampueda –  National Director of Venezuela’s National Police.
8. Nestor Reverol Torres – Venezuela’s Minister of Interior and Justice.
9. Sergio Rivero Marcano –  Commander General of Venezuela’s National Guard.
10. Tarek William Saab –  Venezuela’s Ombudsman.
11. Jesus Suárez Chourio – General Commander of Venezuela’s Army.
12. Iris Varela –  Member of Venezuela’s Presidential Commission for the Constituent Assembly and former Minister of the Penitentiary Service.
13. Simon Alejandro Zerpa – Vice President of Finance for PDVSA, president of Venezuela’s Economic and Social Development Bank (BANDES), president of Venezuela’s National Development Fund (FONDEN).

Pursuant to OFAC guidance, the designation of an official of the government of Venezuela does not mean that the government itself is also blocked. However, OFAC has stressed that U.S. persons should be cautious in any dealings with the Venezuelan government—or any other entity whose leadership includes sanctioned parties—to ensure that they are not engaged in transactions or dealings, directly or indirectly, with any SDNs.

For more details on the Venezuela Sanctions Program, please see Crowell & Moring’s previous Client Alerts on the E.O. issued by President Obama in March 2015, and the Venezuela Sanctions Regulations issued by OFAC in July 2015.

For more information, contact: Cari Stinebower, Jeff Snyder, and Dj Wolff