If you were expecting to see wire transfers boldly coming in from Gazprombank, in the wake of the announcement that the bank was going to facilitate oil profits earned by the OFAC-sanctioned Venezuelan government-owned PDVSA, think again. Gazprombank is a subsidiary of Gazprom, the world's largest oil conglomerate, ans Gazprom has over 100 wholly- or partially-owned subsidiaries throughout the world, including in a number of offshore tax havens where disguising the origin of funds is routine and totally opaque.
My advice is that if you are a compliance officer at a North American or EU financial institution, you familiarize yourself with the list of Gazprom subsidiaries on Wikipedia. This is especially relevant if your client base includes affluent Venezuelan nationals with connections to the present government.
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