Tuesday, February 14, 2017


The SDNTK designation, imposed by OFAC upon Venezuela's new Vice President, Tareck El Aissami, presents compliance officers at US banks with a dilemma; how does one safely engage in any transactions with Venezuelan banks, when even the country's second in command is OFAC- sanctioned ? He allegedly has drug trafficking ties, as well as being involved in the distribution Venezuelan identification to terrorists. Is anything in that country low-risk ?

Add to the mix the sad fact that a full two-thirds of the major money launderers operating in the Republic of Panama, are Venezuelan nationals, busy cleaning their clients' drug profits, proceeds of corruption, criminal profits, and terrorist financing profits, and all that dirty money is coming out of Venezuela, where your bank client is engage in international trade. What is one to do ?

If possible, you can redline all transactions with Venezuela, directly or indirectly, that are passing through your bank, but your exposure to existing debt, letters of credit, outstanding balances, and current client contractual obligations, all complicate your ability to extricate yourself from the financial nightmare that is today's Venezuela.

Perhaps the best thing is to decline any future business, and wind up what you have on your plate,  as quickly as possible, while watching closely for front men, and other evidence of intermediaries. All Venezuelan transactions hereafter should be the subject of enhanced due diligence, lest you find yourself on the short end of a criminal investigation of a former Venezuelan client. You may be moving  drug profits, without even being aware of it; be careful.

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