If you are a compliance officer at an international bank whose clients trade with companies located in Spain, be advised that the Banco de España (Bank of Spain), the country's central bank, is promoting massive evasion of US sanctions by allowing firms trading with Venezuela to funnel their payments through its facilities. This means that, as UAE companies do for Iran with sanctions evasion support, the Government of Spain is doing for Venezuela, freely using its banking structure to allow Venezuela to conduct international trade around existing sanctions.
The Bank of Spain, where it has responded to the charges of sanctions evasion at all, has denied the allegations. Compliance officers in the United States should now secure from their banks' clients engaged in trade with companies located in Spain, sworn End User affidavits, attesting to the fact that Spain is the final destination for their clients' goods and services, and for payments as well. To do otherwise will expose your US bank to potential OFAC Civil Fines and Penalties down the road.
|BANK OF SPAIN|
Under the circumstances, you will probably also want to raise Country Risk for Spain, and conduct Enhanced Due Diligence upon the Spanish companies who your clients are trading with ? Are any of them owned or operated by Venezuelan nationals ?