The Office of Foreign Assets Control of the US Department of the Treasury has designated Banco de Desarrollo Economico y Social de Venezuela (BANDES), a state-owned national development bank, pursuant to Executive Order 13850, as amended by Executive Order 13857. In addition to BANDES, OFAC has designated four additional financial institutions owned or controlled by BANDES — two other Venezuelan banks, an Uruguayan development bank, and a Bolivian bank – for operating in the financial sector of the Venezuelan economy. According to the Department of the Treasury, insiders in the Maduro regime have transformed BANDES and its subsidiaries into vehicles to move funds abroad. Following today’s action, all US property interests of these entities and of entities controlled by them are blocked, and transactions between US persons or persons present in the US and these entities are generally prohibited.
In connection with these designations, OFAC has amended General License 4, “Authorizing New Debt Transactions and Transactions involving Certain Banks related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, or Replacement Parts and Components,” and issued four new Venezuela-related general licenses:
- General License 15 – “Authorizing Transactions Involving Certain Banks Prohibited by Executive Order 13850 for Certain Entities”
- General License 16 – “Authorizing Maintenance of U.S. Person Accounts and Noncommercial, Personal Remittances involving Certain Banks”
- General License 17 – “Authorizing Certain Activities Necessary to Wind Down of Operations or Existing Contracts with Certain Banks”
- General License 18 – “Authorizing Certain Transactions Involving Integracion Administradora de Fondos de Ahorro Previsional, S.A.”