EXPECT INDICTMENTS OF VENEZUELAN GOVERNMENT FIGURES IN UNITED STATES

Justice Aponte

Compliance officers at international banks that number Venezuelan PEPs as clients now have additional issues to deal with. Reports from reliable sources indicate that the cooperation currently being rendered by Venezuelan Supreme Court Justice Eladio Aponte to the Drug Enforcement Administration, and a number of other Venezuelan nationals who are also assisting US law enforcement, will result in major indictments of senior Venezuelan military officers and government officials.

What little information that has surfaced publicly points toward several colonels and generals in the Venezuelan National Guard, and senior government officials, up to and including the ministerial level. Compliance officers at financial institutions in Panama, the Cayman Islands, the Bahamas, and Mexico should now be conducting a complete review of all existing high net-worth Venezuelan clients, updating the information contained in the files, and consider whether to exit those clients who pose an unacceptable level of risk.

Venezuelan National Guard

Having your bank client indicted for narcotics trafficking can result in reputation damage in the press, legal proceedings to seize accounts, and the flight of legitimate clients to your competitors. You should be reevaluating risk well ahead of the expected criminal indictments. This is a serious issues that must be dealt with forthwith, if you are to properly discharge your compliance obligations to your employer. To do otherwise could constitute compliance malpractice.

I wonder what the founder of Venezuelan National Guard would say about his senior officers trafficking in narcotics