Inasmuch it is not known who has been, or will shortly be, indicted in the United States,, and where the evidence will lead, should any of those arrested cooperate against their co-conspirators, there are no safe Venezuelan PEP clients at this point. This means that the prudent move is to exit all such client relationships as soon as possible. Even low-level government officers could be facilitating money laundering operations of their superiors. The appropriate risk management response to these pending indictments is to in sure that there are no Venezuelan government officers, employees, military officers, heads of Venezuelan Government-owned companies, charities, and even NGOs that maintain their principal offices in Venezuela.
This may sound like an extreme action, but no American financial institution needs the negative publicity of being publicly linked to a money laundering operation, because you can be sure that much of the narco-profits are finding their way into the continental United States, and you do not want that type of business to be discovered in your bank.