ARTICLE
21 March 2019

OFAC Designates Russian Bank For Materially Assisting Sanctioned Venezuelan Entity

CW
Cadwalader, Wickersham & Taft LLP

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The U.S. Treasury Department ("Treasury") Office of Foreign Assets Control ("OFAC") designated a Russia-based bank for materially assisting Petróleos de Venezuela S.A. ("PdVSA") ...
United States International Law
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The U.S. Treasury Department ("Treasury") Office of Foreign Assets Control ("OFAC") designated a Russia-based bank for materially assisting Petróleos de Venezuela S.A. ("PdVSA"), which OFAC sanctioned in January 2019 and described as a "vehicle for corruption, embezzlement, and money laundering."

OFAC stated that, pursuant to Executive Order 13850, Evrofinance Mosnarbank ("Evrofinance") "materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the sanctioned entity." According to OFAC, assets of Evrofinance grew over 50 percent during 2018, at a time when many U.S. and other financial institutions cut off ties to the regime of President Nicolas Maduro. OFAC noted that Evrofinance was a major backer of the Petro, a Venezuelan cryptocurrency allegedly designed to help the Maduro regime circumvent U.S. sanctions.

As a result of OFAC's action, all property (and interests in property) of the bank, and of any entities that are owned 50 percent or more by it, are blocked and must be reported to OFAC to the extent such property is located in the United States, or is in the possession or control of U.S. persons. Additionally, U.S. persons generally are prohibited from engaging in any dealings with the bank and its property, and interests in property.

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