Be advised that a law passed in Venezuela, reportedly known as the "Act of Currency Exchange Regime," Article 12, limits the purchase or sale of dollars, by Venezuelan nationals, to no more than USD$10,000 per year. A violation of this statute, according to Venezuelan reports, will result in criminal charges of money laundering. There is no information available yet on fines and/or imprisonment for violations.
Do you have branch employees/clients/customers/vendors who are Venezuelan nationals ? If so, you may want to reexamine any currency exchange practices that you facilitate for them, especially the acquisition of US Dollars, through the exchange of other currencies. It is suggested that you consult with your counsel about this issue; otherwise, you may be unwittingly placing someone at risk.
If you, or your staff, routinely travel to Venezuela, and you carry US Dollars, you also must establish safeguards and policies to avoid becoming entangled in the possible criminal prosecution of Venezuelan nationals that you deal with, due to business transactions in dollars. Watch this one, please.
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