IS YOUR VENEZUELAN BANK CLIENT A SYRIAN EXPAT EVADING US SANCTIONS ?

If you read any Latin American news, you know that Venezuela supports the Syrian Assad regime, and even delivered a tanker full of diesel to a Syrian port recently, helping to fuel the Syrian war machine. What you don't know, however is that there is a substantial population of ethnic Syrians living in Venezuela. The omnipotent Syrian organized crime faction, present in much of Latin America, also wields economic power there, but that's a story for another time.

The most visible Syrian expat, who is a Venezuelan congressman, recently took a leave of absence, with government approval, to fight alongside the Syrian Army. He is not alone; Other Syrian-Venezuelans have also volunteered, and traveled back to Syria to try to defeat the Syrian opposition.

As a US banker, strictly liable for OFAC violations, you might want to check the account activity of your high net-worth Venezuelan clients, and insure that none of them that are Syrian-Venezuelans are possibly breaking the law, and implicating your bank, by:

(1) Sending funds to sanctioned individuals, government-controlled corporations, or PEPs in Syria.
(2) Sending funds to Lebanese branches of Syrian banks.
(3) Trading with sanctioned companies.
(4) Receiving money from family members in the Syrian government.
(5) Purchasing goods, and shipping them to Syria.
(6) Exchanging large quantities of Syrian Pounds (SYP) for US Dollars.

Given the present take-no-prisoners stance of the US regarding sanctions, you do not want to be publicly named & shamed by OFAC on its Civil Penalties press releases. Check your clients, please.