Today, the United States Department of the Treasury Office of Foreign Assets Control (OFAC) designated four individuals pursuant to the Foreign Narcotics Kingpin Designation Act (Kingpin Act). All four of these individuals are senior Venezuelan officials whom OFAC believes to be engaged in material support of the Revolutionary Armed Forces of Colombia’s (FARC) narcotics activities. FARC has been designated as a Foreign Terrorist Organization since 1997, as a Specially Designated Global Terrorist since 2001, and as a significant foreign narcotics trafficker pursuant to the Kingpin Act since 2003.

According to OFAC, these four Venezuelan government officials serve as key facilitators of arms, security, training and other assistance in support of the FARC’s operations in Venezuela. The following individuals were designated:

Amilcar Jesus Figueroa Salazar (“Tino”), a member of Venezuela’s delegation to the Latin American Parliament. OFAC has accused Mr. Salazar of serving as an arms dealer for the FARC. In addition, he is accused of providing training for the FARC.

Cliver Antonio Alcala Cordones, a Major General in the Venezuelan Army, who is alleged to have used his position to establish an arms-for-drugs route with the FARC.

Freddy Alirio Bernal Rosales, a Congressman for the United Socialist Party of Venezuela and former Mayor of the Libertador Municipality of Caracas. Mr. Rosales is accused of facilitating arms sales between the Venezuelan government and the FARC.

Ramon Isidro Madriz Moreno (“Amin”), a Venezuelan intelligence officer accused of coordinating security for the FARC.

Due to these Kingpin Act designations, U.S. persons are generally prohibited from engaging in transactions with any of the aforementioned individuals, lest they face severe civil and criminal penalties. Moreover, any assets that these individuals may have under U.S. jurisdiction are now blocked.

Some time ago, I wrote about the growing connection between Iran and Venezuela and that such connection could one day lead to sanctions against Venezuela. While today’s designations of Venezuelan officials are not related to any connection with Iran, it does tend to show that OFAC and the U.S. government are looking at Venezuela and its government officials for sanctions targeting. It would be wise for U.S. persons engaging in business in relation to Venezuela to carefully screen the parties with whom they transact and to take steps to ensure they are in full compliance with U.S. economic sanctions that may impact their transactions in Venezuela.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com.