Yesterday, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the implementation of sanctions against four individuals and one entity. Two of the individuals, Mustafa Badr al-Din and Talal Hamiyah, were designated pursuant to Executive Order 13224 and the Global Terrorism Sanctions Regulations. Another individual, Hassan Nasrullah, a well known Hezbollah leader, was designated pursuant to the Syria program for his participation in assisting the Assad government. This designation was somewhat pointless, as Nasrullah is already designated under a myriad of other OFAC administered sanctions programs. The final individual designated, Roberto Manuel Lopez Pedrigon, a Venezuelan national was designated pursuant to the Foreign Narcotics Kingpin Designation Act. A company affiliated with him, Constructadora FR De Venezuela, C.A., was also designated.

As is the case with listings such as the Kingpin designations, the Terrorism designations, and Syria designations, U.S. persons are prohibited from engaging in transactions with these designated individuals and entities, and any assets which they have in the U.S. or which come under U.S. jurisdiction should be blocked. The penalties for violating these prohibitions vary depending on which designation one looks at. For example, the Syria and Terrorist designations fall under the International Emergency Economic Powers Act (IEEPA), while the Kingpin designation falls under the Foreign Narcotics Kingpin Designation Act. Both of these statutes have their own penalties for violating their prohibitions.

Turning to the title of this post, I have already addressed why one of the designations is meaningless. The one that is interesting to me is the Venezuelan who was designated. I have been writing for some time that I believe Venezuela will be the next hot bed for sanctions targets. This is due to the allegations that they are closely tied to Iran, as well as with South American narcotics trafficking activities. Earlier this year two other Venezuelans, one a high ranking government official, were also designated by OFAC. Those designations and the one we saw yesterday could be a sign of things to come as it seems OFAC is shifting its attention towards 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.