TRADE WITH VENEZUELA HAS UNIQUE PITFALLS

Last week, in US District Court in Florida, a third Venezuelan national, Alberto Pichardo*, entered a plea of guilty to charges of Conspiracy to Violate the Arms Export Control Act. The defendants conspired to sell to the Government of Venezuela F-16 fighter jet parts, aircraft engines, munitions and engines for unmanned aerial vehicles (UAV). Export of these items to Venezuela is strictly prohibited.

Remember the recent disclosure that Venezuela dismantled shipped an F-16 to Iran, together with pilots to assist in training Iran's air defence system in how to detect and shoot down invading aircraft.. Israel, Iran's most likely adversary, employs the F-16 extensively.

Anything that your bank clients are shipping to Venezuela may transshipped straight to Iran. Dual-purpose goods, in particular, are a danger. You do not want your bank to be named as a facilitator of WMD or ballistic missile sanctions evasion. Check all your clients' documents carefully before accepting payments for exports, please.
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*One defendant has not pled out. United States vs.  Alberto Pichardo,  Case No.: 12-cr-20478 (SD FL).