Mr. Sanctions

Category: Venezuela

  • February 6, 2026: Friday FAQs for OFAC Venezuela program

    Announced late Friday:

    1235. Does Venezuela General License (GL) 46 authorize downstream trading activities in Venezuelan-origin oil? 

    Yes. Once a transaction with the Government of Venezuela (GOV), Petróleos de Venezuela, S.A. (PdVSA), or its majority-owned subsidiaries (PdVSA Entities) has been completed pursuant to GL 46, and the interest—including any future or contingent interest—of a blocked entity is fully extinguished, then the oil can be freely sold, resold, and traded by any downstream purchaser, including entities that are not established U.S. entities, as defined in GL 46.

    Released on Feb 06, 2026

    Venezuela Sanctions

    1234. How does a financial institution verify a transaction is compliant with Venezuela General License (GL) 46? 

    In connection with its normal due diligence, a financial institution may rely on the statements of its customer that the transaction is consistent with the terms of GL 46, unless it knows or has reason to know otherwise.

    Released on Feb 06, 2026

    Venezuela Sanctions

    1233. Are all entities engaged in a transaction authorized by Venezuela General License (GL) 46 required to have contracts with the dispute resolution requirement included in paragraph (a)(1)? 

    No. The dispute resolution requirement in paragraph (a)(1) of GL 46 applies only to contracts governing transactions undertaken by an established U.S. entity when the contract is with the Government of Venezuela (GOV), Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (PdVSA Entities).

    This requirement does not apply to indirect parties or indirect counterparties involved in transactions authorized by GL 46, such as downstream transactions involving the provision of shipping, insurance, or other services to an entity engaged in a transaction involving PdVSA. For example, this provision would not apply to a contract between an insurance provider and an established U.S. entity engaged in a transaction with PdVSA to purchase Venezuelan-origin oil (though it would apply to the contract between the U.S. entity and PdVSA).

    Released on Feb 06, 2026

    Venezuela Sanctions

    1232. What does OFAC consider “commercially reasonable terms,” as described in Venezuela General License (GL) 46? 

    “Commercially reasonable terms” means terms that are consistent with prevailing market and industry standards for like or similar products produced by a company of similar size and scope, while taking into account characteristics such as quality, quantity, pricing, performance, and safety, among others. Commercially reasonable terms include terms related to, among other things, the governance, economics, operations, and legal/compliance requirements of a contract negotiated at arm’s length between two or more parties.

    Released on Feb 06, 2026

    Venezuela Sanctions

    1231. What entities or jurisdictions are excluded from transactions authorized under Venezuela General License (GL) 46? 

    GL 46 excludes the involvement of persons located in or organized under the laws of the Russia Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, and the Republic of Cuba—as well as any entity owned or controlled, directly or indirectly (including by or in a joint venture with) any of the foregoing.

    In addition, GL 46 does not authorize transactions with any Venezuelan or U.S. entity that is owned or controlled by, or in a joint venture with, a person located in or organized under the laws of the People’s Republic of China. However, GL 46 does not restrict the resale of Venezuelan-origin oil to China by an established U.S. entity.

    Released on Feb 06, 2026

    Venezuela Sanctions

    1230. Can an entity that is not an “established U.S. entity” be involved in transactions authorized by Venezuela General License (GL) 46? 

    Yes. Non-U.S. persons may engage in transactions or provide services that are ordinarily incident and necessary to the established U.S. entity’s transactions authorized by GL 46. Such activities or ancillary services could include: providing transportation and logistics services to an established U.S. entity for the export of Venezuelan-origin oil; providing marine insurance to vessels chartered by established U.S. entities to transport Venezuelan-origin oil; the financing of related cargoes or receivables; leasing storage facilities for Venezuelan-origin oil purchased by an established U.S. entity; or contracting with established U.S. entities for repair or maintenance services of infrastructure necessary to effectuate the export of oil from Venezuela, among others.

    Please see FAQ 1235 for additional information regarding authorized downstream trading activities.

    Please see FAQ 1231 for certain individuals and jurisdictions excluded from the scope of GL 46.

    Released on Feb 06, 2026

    Venezuela Sanctions

    1229. Venezuela General License (GL) 46 authorizes certain activity by an “established U.S. entity.” What is an “established U.S. entity” for purposes of GL 46? 

    For purposes of GL 46, the term “established U.S. entity” means any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025.

    GL 46 is designed to help ensure that the oil exported from Venezuela will be through legitimate and authorized channels, consistent with U.S. law and President Trump’s efforts to restore prosperity, safety, and security to the United States and Venezuela. Established U.S. companies should be familiar with complying with U.S. laws and regulations, including U.S. sanctions regulations, which will help ensure their ability to market Venezuelan oil in the global marketplace for the benefit of the United States, Venezuela, and our allies.

    Released on Feb 06, 2026

    Venezuela Sanctions

    1228. Does Venezuela General License (GL) 46, “Authorizing Certain Activities Involving Venezuelan-Origin Oil,” authorize exploration activity or negotiations for new investment activities? 

    No. GL 46 authorizes the purchase, exportation, and sale of Venezuelan-origin oil that has already been extracted, including the refining of such oil. It does not authorize other exploration or production activities, such as conducting geological surveys, drilling wells, or extracting oil from fields in Venezuela, nor does it authorize activities related to investment in the Venezuelan oil sector, such as negotiations with Petróleos de Venezuela, S.A. (PdVSA) to enter into a contract to develop or operate oil fields, blocks, or other concessions. For more information on what transactions are authorized by GL 46, see FAQ 1227.

    Released on Feb 06, 2026

    Venezuela Sanctions

    1227. What activities does Venezuela General License (GL) 46 authorize? 

    GL 46 authorizes activities that are ordinarily incident and necessary to the lifting (which refers to the physical loading and removal of oil from a terminal, storage facility, or production site for delivery to a buyer), exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil by an established U.S. entity, which may include:

    • engaging in commercial, legal, and technical discussions necessary to scope purchases of Venezuelan-origin oil, including with third-party legal, commercial, or due diligence consultants;
    • conducting safety, environmental, and other relevant inspections, including site surveys;
    • arranging logistics, security services, delivery points, and shipping preparation, including obtaining marine insurance and engaging with relevant port or maritime authorities of the Government of Venezuela (GOV) or their personnel;
    • conducting certain downstream activities, including the refining and resale of Venezuelan-origin oil;
    • coordinating payment structures, including payments in the form of swaps of oil, diluents, or refined petroleum products, among others;
    • making required repairs and maintenance to pipeline, storage, or port infrastructure necessary to effectuate the loading of vessels; or
    • the financing of related cargos or receivables.

    Notably, GL 46 does not authorize:

    • transactions that are not on commercially reasonable terms;
    • payment in gold or the use of debt swaps;
    • payments denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;
    • any transaction involving a person located in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled by or in a joint venture with such persons;
    • transactions involving an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China;
    • the unblocking of any property blocked pursuant to the Venezuela Sanctions Regulations; or
    • any transaction involving a blocked vessel.

    For information on how an entity that is not an “established U.S. entities” (including non-U.S. entities) can be involved in transactions authorized by GL 46, see FAQ 1230.

    Released on Feb 06, 2026

    Venezuela Sanctions

    1226. Does “Venezuelan-origin oil” as referenced in Venezuela General License (GL) 46, “Authorizing Certain Activities Involving Venezuelan-Origin Oil,” include petroleum products? 

    Yes. Consistent with the term “Venezuelan oil” as defined in section 5(a) of Executive Order 14245, “Imposing Tariffs on Countries Importing Venezuelan Oil,” the term “Venezuelan-origin oil” means crude oil or petroleum products extracted, refined, or exported from Venezuela, regardless of the nationality of the entity involved in the production or sale of such crude oil or petroleum products.

    As defined by the U.S. Energy Information Administration (EIA), petroleum products include unfinished oils, liquefied petroleum gases, pentanes plus, aviation gasoline, motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, kerosene, distillate fuel oil, residual fuel oil, petrochemical feedstocks, special naphthas, lubricants, waxes, petroleum coke, asphalt, road oil, still gas, and miscellaneous products obtained from the processing of crude oil (including lease condensate), natural gas, and other hydrocarbon compounds. In keeping with the EIA’s standard definition, petroleum products do not include natural gas, liquefied natural gas, biofuels, methanol, and other non-petroleum fuels.

    Accordingly, crude oil blends such as Merey 16 or bitumen blends, as well as petroleum products or byproducts, including gasoline, asphalt, flexicoke, and petroleum coke, are considered “Venezuelan-origin oil” for the purposes of GL 46.

    Released on Feb 06, 2026

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  • February 3, 2026: What’s a Diluent?

    venezuela_gl47Download

    So, what are diluents and why are they important?

    Based on the text of General License 47, issued February 3, 2026, here is an updated explanation of what this authorization means, what diluents are, and how they will be used.

    1. What are “Diluents”? (The Simple Analogy)

    In the oil industry, a diluent is essentially a thinner.

    Think of Venezuela’s crude oil like cold peanut butter. It is incredibly thick and sticky. If you try to push it through a pipeline (which is just a giant straw), it gets stuck. It is physically too heavy to flow on its own.

    A diluent is a lighter fluid—often a very light oil or a refined product like naphtha (similar to gasoline)—that you mix into the peanut butter. This turns the thick paste into a runny liquid that can easily flow through pipes to reach ports and refineries1.

    2. Why does Venezuela need U.S. Diluents?

    Venezuela has massive oil reserves, but most of it is “extra-heavy” crude.

    • The Problem: Without a thinner, this oil cannot be exported. It stays stuck in the ground or in storage tanks.
    • The Change: Previously, Venezuela often had to rely on swaps or shady deals to get these thinning agents, sometimes from sanctioned adversaries.
    • The Solution: General License 47 specifically authorizes the sale of U.S.-origin diluents to Venezuela2. This allows Venezuela to legally buy the “thinner” it needs from U.S. companies to get its oil industry moving again.

    3. How will they be used? (The Process)

    The license authorizes the entire supply chain (“exportation… supply, storage, marketing, delivery”)3. The process will likely look like this:

    1. Import: U.S. companies ship the light oil (diluent) to Venezuelan ports.
    2. Blending: Venezuela pumps this light oil to its fields and mixes it with their heavy crude.
    3. Export: The new mixture is pumped back to the coast. The heavy oil can now be sold on the global market because it is liquid enough to load onto tankers.

    4. Key Constraints in General License 47

    This license is not a free-for-all; it is designed to keep the trade under tight U.S. supervision.

    • U.S. Control: The license requires that any contract for these diluents must be governed by U.S. law, and any legal disputes must be resolved in the United States4. This gives U.S. courts jurisdiction over the deals.
    • Pushing Out Adversaries: The license strictly forbids any involvement with Iran, North Korea, or Cuba (or any joint ventures involving them)5. This is likely a strategic move to replace Iranian diluents (which Venezuela has used recently) with U.S. supplies.
    • Normal Business Only: Venezuela cannot pay with “debt swaps,” gold, or cryptocurrency (like the “petro”)6. They must use “commercially reasonable” payment terms, likely meaning standard cash or wire transfers.
    • Reporting: Companies must report exactly who is involved and how much is being sold to the U.S. State Department and Department of Energy within 10 days of the first sale7777.

    Summary: The U.S. is allowing Venezuela to buy American “paint thinner” for its oil, but only if they cut out Iran/Cuba, play by U.S. legal rules, and avoid using gold or crypto for payments.

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  • February 2, 2026: and U? Yet another new version of Venezuela GL 5 (and an updated FAQ, too)

    This is the General License (GL) that authorizes transactions on PDVSA’s (Petróleos de Venezuela SA) 8.5% bond after a specified date… which this version pushes back another 6 weeks or so:

    venezuela_gl5u_0Download

    and the related Frequently Asked Question (FAQ) was updated, too:

    595. What does Venezuela-related General License 5U authorize?

    The President issued Executive Order (E.O.) 13835 on May 21, 2018. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity owned 50 percent or more by the GOV. One effect of subsection 1(a)(iii) is to require authorization before U.S. persons may engage in certain transactions regarding any equity interest in an entity owned 50 percent or more by the GOV. Subsequent to the issuance of E.O. 13835, OFAC received inquiries about how and whether subsection 1(a)(iii) of E.O. 13835 could affect the ability to enforce bondholder rights to the CITGO shares serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 percent bond. OFAC issued General License (GL) 5 on July 19, 2018, which removed E.O. 13835 as an obstacle to holders of the PdVSA 2020 8.5 percent bond gaining access to their collateral.

    General License 5 was replaced and superseded by General License 5A on October 24, 2019 with a delay in the effectiveness of the authorization in the general license. Since that date, OFAC has extended the delay in effectiveness multiple times. Most recently, OFAC issued General License 5U on February 2, 2026, which further delays the effectiveness of the authorization in GL 5 until March 20, 2026. Between October 24, 2019 and March 20, 2026 (the date the authorization in General License 5U becomes effective), there is no authorization in effect that licenses against subsection 1(a)(iii) of E.O. 13835 applicable to the holders of the PdVSA 2020 8.5 percent bond. As a result, during such period, transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond are prohibited, unless specifically authorized by OFAC.

    To the extent an agreement may be reached on proposals to restructure or refinance payments due to the holders of the PdVSA 2020 8.5 percent bond, additional licensing requirements may apply. OFAC would encourage parties to apply for a specific license and would have a favorable licensing policy toward such an agreement.

    Date Updated: February 2, 2026

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  • January 29, 2026: OFAC issues new Venezuela General License

    Venezuela General License 46, Authorizing Certain Activities Involving Venezuelan-Origin Oil

    venezuela_gl46Download

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  • January 13, 2026: SECO updates to Congo, Russia, Venezuela programs

    So, it turns out that Gemini cannot process formatting in a PDF – like the underlining or strike-through formatting in SECO listings… while there are workarounds, they rely on a lot of manual manipulation of the data in the PDF.

    So, I’ll display the PDFs of the delta files (they call them that – it’s in the file name), and list all the other components, such as the sanctions program page and the FINMA notice. Just in case it wasn’t obvious, for changed records, underlined text is new information, and text with strike-through formatting is information being deleted.

    So, the Swiss sanctions program for the Democratic Republic of the Congo (DRC) has updates to 3 individual listings:

    Kongo_Delta_2026-01-12Download

    The Swiss Russia program has added individuals, entities and cargo vessels (listed as “Objects”), plus a bunch of amended listings:

    Situation in der Ukraine Delta 2026-01-12Download

    The Swiss Venezuela program has amended 4 individual designations:

    Venezuela_Delta_2026-01-12Download

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  • January 5, 2026: Switzerland freezes Venezuelan assets

    Swiss Maduro PRDownload

    Here’s the law (in French – English is not one of the 4 recognized national languages)

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  • Working Backwards: December 12, 2025 OFAC Designations and Designation Updates – with Formatting Corrections and Enhancements

    Counter Narcotics Designations; Venezuela-related Designations; Non-Proliferation Designation Updates

    Treasury Press Release: Treasury Targets Illegitimate Maduro Regime Insiders and Sanctions Evaders in Venezuela’s Oil Sector

    Additions:

    The following individuals have been added to OFAC’s SDN List:

    OFAC Program: [ILLICIT-DRUGS-EO14059] Executive Order 14059 – Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade

    CAMPO FLORES, Efrain Antonio

    • Address: Caracas, Venezuela
    • DOB: 25 Aug 1986
    • POB: Valencia, Venezuela
    • Nationality: Venezuela
    • Gender: Male
    • Cedula No.: 18330183 (Venezuela)
    • Passport: 081303148 (Venezuela) expires 28 Nov 2018
    • Party Type: Individual

    FLORES DE FREITAS, Franqui Francisco

    • Address: Caracas, Venezuela
    • DOB: 14 Aug 1985
    • POB: Caracas, Venezuela
    • Nationality: Venezuela
    • Gender: Male
    • Cedula No.: 17751244 (Venezuela)
    • Passport: 066981222 (Venezuela) expires 24 Jan 2018
    • Party Type: Individual

    Supplemental Information: Efrain Antonio Campo Flores and Franqui Francisco Flores de Freitas are the nephews of Cilia Flores, the wife of Nicolas Maduro. They are being designated for their involvement in illicit drug trafficking activities.

    OFAC Program: [VENEZUELA-EO13850] Executive Order 13850 – Blocking Property of Additional Persons Contributing to the Situation in Venezuela

    CARRETERO NAPOLITANO, Ramon

    • Address: Panama City, Panama
    • DOB: 08 May 1965
    • POB: Colon, Panama
    • Nationality: Panama
    • Gender: Male
    • Cedula No.: 388114 (Panama)
    • Passport: 1874513 (Panama) expires 28 Mar 2017
    • Party Type: Individual

    Supplemental Information: Ramon Carretero Napolitano is a Panamanian businessman designated for operating in the oil sector of the Venezuelan economy and facilitating sanctions evasion for the Maduro regime.

    OFAC Program: [VENEZUELA] Venezuela Sanctions Regulations, 31 C.F.R. part 591

    MALPICA FLORES, Carlos Erik

    • Address: Naguanagua, Carabobo, Venezuela
    • DOB: 17 Sep 1972
    • Nationality: Venezuela
    • Gender: Male
    • Cedula No.: 11810943 (Venezuela)
    • Party Type: Individual

    Supplemental Information: Carlos Erik Malpica Flores is a former official of the Government of Venezuela and the nephew of Cilia Flores. He previously served as the National Treasurer and Vice President of Finance for PDVSA. He is designated for being a current or former official of the Government of Venezuela.

    The following entities have been added to OFAC’s SDN List:

    OFAC Program: [VENEZUELA-EO13850] Executive Order 13850 – Blocking Property of Additional Persons Contributing to the Situation in Venezuela

    ARCTIC VOYAGER INCORPORATED

    • AKA: ARCTIC VOYAGER INC
    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 08 Nov 2024
    • Identification Number: IMO 0109600
    • Business Registration Number: 128742 (Marshall Islands)

    FULL HAPPY LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 03 Mar 2023
    • Identification Number: IMO 6405624
    • Business Registration Number: 118736 (Marshall Islands)

    MYRA MARINE LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 24 Sep 2024
    • Identification Number: IMO 0088934
    • Business Registration Number: 128049 (Marshall Islands)

    POWEROY INVESTMENT LIMITED

    • AKA: POWEROY INVESTMENT LTD
    • Address: Virgin Islands, British
    • Identification Number: IMO 6438512

    READY GREAT LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 06 Jul 2023
    • Identification Number: IMO 0017035
    • Business Registration Number: 120806 (Marshall Islands)

    SINO MARINE SERVICES LIMITED

    • AKA: SINO MARINE SERVICES LTD
    • Address: 14, Wells View Drive, Bromley, Kent BR2 9UL, United Kingdom
    • Organization Established Date: 01 Jan 2016
    • Identification Number: IMO 5967460
    • Company Number: 10214578 (United Kingdom)

    Supplemental Information: These entities are part of a sanctions evasion network established to facilitate the illicit export of Venezuelan oil.

    The following vessels have been added to OFAC’s SDN List:

    OFAC Program: [VENEZUELA-EO13850] Executive Order 13850 – Blocking Property of Additional Persons Contributing to the Situation in Venezuela

    H. CONSTANCE (3E2177)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2002
    • Vessel Registration Identification: IMO 9237773
    • MMSI: 352002009
    • Party Type: Vessel
    • Linked to: POWEROY INVESTMENT LIMITED

    KIARA M (3E2278)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2004
    • Vessel Registration Identification: IMO 9285823
    • MMSI: 352002348
    • Party Type: Vessel
    • Linked to: ARCTIC VOYAGER INCORPORATED

    LATTAFA (3E2298)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2003
    • Vessel Registration Identification: IMO 9245794
    • Party Type: Vessel
    • Linked to: READY GREAT LIMITED

    MONIQUE (E5U5122)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Cook Islands
    • Vessel Year of Build: 2005
    • Vessel Registration Identification: IMO 9311270
    • MMSI: 518999141
    • Party Type: Vessel
    • Linked to: FULL HAPPY LIMITED

    TAMIA (VRXC8)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Hong Kong
    • Vessel Flag: Other Vessel Flag China
    • Vessel Year of Build: 2006
    • Vessel Registration Identification: IMO 9315642
    • MMSI: 477186300
    • Party Type: Vessel
    • Linked to: SINO MARINE SERVICES LIMITED

    WHITE CRANE (HOA6213)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2007
    • Vessel Registration Identification: IMO 9323429
    • MMSI: 352003199
    • Party Type: Vessel
    • Linked to: MYRA MARINE LIMITED

    Supplemental Information: These vessels are part of a shadow fleet used to transport Venezuelan oil in violation of U.S. sanctions.

    Amendments:

    Specially Designated Nationals List Update

    The following changes have been made to OFAC’s SDN List:

    OFAC Programs:

    • [NPWMD] Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544
    • [IFSR] Iranian Financial Sanctions Regulations, 31 C.F.R. part 561

    ADVANCED INFORMATION AND COMMUNICATION TECHNOLOGY CENTER

    • AKA:
      • AICTC
      • ADVANCED INFORMATION AND COMMUNICATION TECHNOLOGY RESEARCH INSTITUTE
      • “AICT”
    • Address: No. 5, Golestan Alley, Shahid Ghasemi St., Sharif University of Technology, Tehran, Iran
    • Website: www.aictc.ir
    • Additional Sanctions Information – Subject to Secondary Sanctions

    Supplemental Information: None

    List of Changes:

    • Field Name: AKA
      • Added: ADVANCED INFORMATION AND COMMUNICATION TECHNOLOGY RESEARCH INSTITUTE
      • Added: “AICT”

    RAHIMIAN, Pezhman

    • AKA: RAHIMIAN, Pejman
    • Address: Iran
    • DOB: 29 Aug 1977
    • POB: Esfahan, Esfahan Province, Iran
    • Nationality: Iran
    • Additional Sanctions Information – Subject to Secondary Sanctions
    • Gender: Male
    • National ID No.: 1285917855 (Iran)
    • Party Type: Individual
    • Linked to: ATOMIC ENERGY ORGANIZATION OF IRAN

    Supplemental Information: None

    List of Changes:

    • Field Name: DOB
      • Added: 29 Aug 1977

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  • Working Backwards: December 19, 2025 OFAC Designations – with Formatting Corrections and Enhancements

    You’ll notice that Gemini grouped related designations together for the Supplemental Information derived from the Treasury press release – smart way to do things. There are some times you say “that’s actually an improvement”. In the PAARSS update, it only listed the removal of the Caesar Act program after the last listing, since the change was actually being made to all. That one was too confusing – so I made it more obvious in the prompt where the discovery and documentation of changes started and ended. A simple statement like “end of listing reformatting” is very effective – like parentheses…

    Venezuela-related Designations; Issuance of Venezuela-related General License; Publication of Amended Venezuela-related Frequently Asked Question

    Treasury Press Release: Treasury Targets Family Members and Associates of Maduro Regime

    Additions:

    The following individuals have been added to OFAC’s SDN List:

    OFAC Program: [VENEZUELA-EO13850] Executive Order 13850 – Blocking Property of Additional Persons Contributing to the Situation in Venezuela

    CARRETERO NAPOLITANO, Roberto

    • Address: Panama
    • DOB: 20 Aug 1976
    • POB: Colon, Panama
    • Nationality: Panama
    • Gender: Male
    • Cedula No.: 3701218 (Panama)
    • Party Type: Individual

    CARRETERO NAPOLITANO, Vicente Luis

    • Address: Panama
    • DOB: 06 Oct 1966
    • POB: Colon, Panama
    • Nationality: Panama
    • Gender: Male
    • Cedula No.: 3901065 (Panama)
    • Party Type: Individual

    Supplemental Information: Roberto and Vicente Luis Carretero Napolitano are Panamanian businessmen designated for operating in the gold sector of the Venezuelan economy. They are associates of the Maduro regime and have been involved in illicit financial activities supporting the regime.

    FLORES DE MALPICA, Eloisa

    • Address: Venezuela
    • DOB: 01 Dec 1948
    • POB: Tinaquillo, Venezuela
    • Nationality: Venezuela
    • Gender: Female
    • Cedula No.: 3989591 (Venezuela)
    • Party Type: Individual

    HURTADO PEREZ, Damaris del Carmen

    • Address: Venezuela
    • DOB: 03 Jul 1975
    • POB: Barinas, Venezuela
    • Nationality: Venezuela
    • Gender: Female
    • Cedula No.: 12207076 (Venezuela)
    • Party Type: Individual

    MALPICA FLORES, Iriamni

    • Address: Venezuela
    • DOB: 15 Oct 1975
    • POB: Caracas, Venezuela
    • Nationality: Venezuela
    • Gender: Female
    • Cedula No.: 12761280 (Venezuela)
    • Party Type: Individual

    MALPICA HURTADO, Erica Patricia

    • Address: Venezuela
    • DOB: 14 Jun 2001
    • POB: Valencia, Venezuela
    • Nationality: Venezuela
    • Gender: Female
    • Cedula No.: 28331171 (Venezuela)
    • Party Type: Individual

    MALPICA TORREALBA, Carlos Evelio

    • Address: Venezuela
    • DOB: 20 Feb 1947
    • POB: Tinaquillo, Venezuela
    • Nationality: Venezuela
    • Gender: Male
    • Cedula No.: 3056173 (Venezuela)
    • Party Type: Individual

    Supplemental Information: These individuals are family members of Cilia Flores, the wife of Nicolas Maduro, and key figures in the Maduro regime’s network. They have been designated for their involvement in corruption and for being officials of the Government of Venezuela or family members of such officials.

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  • Working Backwards: December 31, 2025 OFAC Designations – with Formatting Corrections and Enhancements

    Venezuela-related Designations

    Treasury Press Release: Treasury Targets Oil Traders Engaged in Sanctions Evasion for Maduro Regime

    Additions:

    The following entities have been added to OFAC’s SDN List:

    [VENEZUELA-EO13850] – Executive Order 13850 – Blocking Property of Additional Persons Contributing to the Situation in Venezuela

    ARIES GLOBAL INVESTMENT LTD

    AKAs: ARIES GLOBAL INVESTMENT LIMITED

    • Address: Room 2611, 26th Floor, Southeast Technology R&D Center, 438, Jincheng Lu, Xiaoshan Qu, Hangzhou, Zhejiang, China
    • Address: Rm A 20/F ZJ 300, 300 LOCKHART RD, Wan Chai, Hong Kong, China
    • Identification Number: IMO 0052971
    • Registration Number: 76957722 (Hong Kong) issued 19 Aug 2024

    Based on the Treasury press release, this entity was designated for operating in the oil sector of the Venezuelan economy. It is the registered owner of the vessel DELLA, which has transported Venezuelan oil.

    CORNIOLA LIMITED

    AKAs: CORNIOLA LTD

    • Address: 149, Donggang Jiedao, Putuo Qu, Zhoushan, Zhejiang 316100, China
    • Address: Rm 909 G 9/F Hunghom Coml Ctr Twr A, 39 Ma Tau Wai Rd, Hunghom, Kowloon, Hong Kong, China
    • Identification Number: IMO 6434228
    • Registration Number: 75612503 (Hong Kong) issued 14 Aug 2023

    According to the Treasury press release, this entity was designated for operating in the oil sector of the Venezuelan economy. It is the registered owner of the vessel NORD STAR, which has transported Venezuelan oil.

    KRAPE MYRTLE CO LTD

    • Address: 149 Donggang Jiedao, Putuo Qu, Zhoushan, Zhejiang 316100, China
    • Address: Rm D5 5/F King Yip Fty Bldg, 59 King Yip St, Kwun Tong, Kowloon, Hong Kong, China
    • Identification Number: IMO 6342210
    • Registration Number: 74094750 (Hong Kong) issued 31 May 2022

    The Treasury press release states this entity acts as the ship manager and operator of the NORD STAR and was designated for operating in the oil sector of the Venezuelan economy.

    WINKY INTERNATIONAL LIMITED

    • Address: 14th Floor, Guangdong Investment Tower, 148 Connaught Road Central, Hong Kong, China
    • Address: Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 01 Nov 2024
    • Registration Number: 128617 (Marshall Islands)

    Based on the Treasury press release, this entity was designated for operating in the oil sector of the Venezuelan economy. It is the registered owner of the vessel ROSALIND, which has transported Venezuelan oil.

    The following vessels have been added to OFAC’s SDN List:

    [VENEZUELA-EO13850] – Executive Order 13850 – Blocking Property of Additional Persons Contributing to the Situation in Venezuela

    DELLA (VRUB7)

    • Vessel Type: Crude Oil Tanker
    • Flag: Hong Kong
    • Other Vessel Flag: China
    • Vessel Year of Build: 2001
    • Vessel Registration Identification: IMO 9227479
    • MMSI: 477714500

    Linked to: ARIES GLOBAL INVESTMENT LTD

    The Treasury press release identifies this vessel as blocked property in which ARIES GLOBAL INVESTMENT LTDhas an interest. It has been used to transport Venezuelan oil.

    NORD STAR (3E7463)

    • Vessel Type: Crude Oil Tanker
    • Flag: Panama
    • Vessel Year of Build: 2006
    • Vessel Registration Identification: IMO 9323596
    • MMSI: 352003296

    Linked to: KRAPE MYRTLE CO LTD; CORNIOLA LIMITED

    According to the Treasury press release, this vessel is blocked property in which CORNIOLA LIMITED and KRAPE MYRTLE CO LTD have an interest. It has been used to transport Venezuelan oil.

    ROSALIND

    AKAs: LUNAR TIDE

    • Vessel Type: Oil Products Tanker
    • Flag: Guinea
    • Vessel Year of Build: 2004
    • Vessel Registration Identification: IMO 9277735

    Linked to: WINKY INTERNATIONAL LIMITED

    The Treasury press release identifies this vessel as blocked property in which WINKY INTERNATIONAL LIMITEDhas an interest. It has been used to transport Venezuelan oil.

    VALIANT (VRXH3)

    • Vessel Type: Crude Oil Tanker
    • Flag: Hong Kong
    • Other Vessel Flag: China
    • Vessel Year of Build: 2009
    • Vessel Registration Identification: IMO 9409247
    • MMSI: 477206500

    Linked to: ARIES GLOBAL INVESTMENT LTD

    Based on the Treasury press release, this vessel is identified as blocked property in which ARIES GLOBAL INVESTMENT LTD has an interest.

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    , ,

  • Half the battle is the reformatting

    Here’s Wednesday’s designations, with some fixes to my understanding of the format (unlike other formats, the field name/label in OFAC listings are not really differentiated by formatting or separator character), as well as some reformatting so it’s easier on the eyes to tease apart the various sections, listings and fields:

    Venezuela-related Designations

    Treasury Press Release: Treasury Targets Oil Traders Engaged in Sanctions Evasion for Maduro Regime

    Additions:

    The following entities have been added to OFAC’s SDN List:

    [VENEZUELA-EO13850] – Executive Order 13850 – Blocking Property of Additional Persons Contributing to the Situation in Venezuela

    ARIES GLOBAL INVESTMENT LTD

    AKAs: ARIES GLOBAL INVESTMENT LIMITED

    • Address: Room 2611, 26th Floor, Southeast Technology R&D Center, 438, Jincheng Lu, Xiaoshan Qu, Hangzhou, Zhejiang, China
    • Address: Rm A 20/F ZJ 300, 300 LOCKHART RD, Wan Chai, Hong Kong, China
    • Identification Number: IMO 0052971
    • Registration Number: 76957722 (Hong Kong) issued 19 Aug 2024

    Based on the Treasury press release, this entity was designated for operating in the oil sector of the Venezuelan economy. It is the registered owner of the vessel DELLA, which has transported Venezuelan oil.

    CORNIOLA LIMITED

    AKAs: CORNIOLA LTD

    • Address: 149, Donggang Jiedao, Putuo Qu, Zhoushan, Zhejiang 316100, China
    • Address: Rm 909 G 9/F Hunghom Coml Ctr Twr A, 39 Ma Tau Wai Rd, Hunghom, Kowloon, Hong Kong, China
    • Identification Number: IMO 6434228
    • Registration Number: 75612503 (Hong Kong) issued 14 Aug 2023

    According to the Treasury press release, this entity was designated for operating in the oil sector of the Venezuelan economy. It is the registered owner of the vessel NORD STAR, which has transported Venezuelan oil.

    KRAPE MYRTLE CO LTD

    • Address: 149 Donggang Jiedao, Putuo Qu, Zhoushan, Zhejiang 316100, China
    • Address: Rm D5 5/F King Yip Fty Bldg, 59 King Yip St, Kwun Tong, Kowloon, Hong Kong, China
    • Identification Number: IMO 6342210
    • Registration Number: 74094750 (Hong Kong) issued 31 May 2022

    The Treasury press release states this entity acts as the ship manager and operator of the NORD STAR and was designated for operating in the oil sector of the Venezuelan economy.

    WINKY INTERNATIONAL LIMITED

    • Address: 14th Floor, Guangdong Investment Tower, 148 Connaught Road Central, Hong Kong, China
    • Address: Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 01 Nov 2024
    • Registration Number: 128617 (Marshall Islands)

    Based on the Treasury press release, this entity was designated for operating in the oil sector of the Venezuelan economy. It is the registered owner of the vessel ROSALIND, which has transported Venezuelan oil.

    The following vessels have been added to OFAC’s SDN List:

    [VENEZUELA-EO13850] – Executive Order 13850 – Blocking Property of Additional Persons Contributing to the Situation in Venezuela

    DELLA (VRUB7)

    • Vessel Type: Crude Oil Tanker
    • Flag: Hong Kong
    • Other Vessel Flag: China
    • Vessel Year of Build: 2001
    • Vessel Registration Identification: IMO 9227479
    • MMSI: 477714500

    Linked to: ARIES GLOBAL INVESTMENT LTD

    The Treasury press release identifies this vessel as blocked property in which ARIES GLOBAL INVESTMENT LTDhas an interest. It has been used to transport Venezuelan oil.

    NORD STAR (3E7463)

    • Vessel Type: Crude Oil Tanker
    • Flag: Panama
    • Vessel Year of Build: 2006
    • Vessel Registration Identification: IMO 9323596
    • MMSI: 352003296

    Linked to: KRAPE MYRTLE CO LTD; CORNIOLA LIMITED

    According to the Treasury press release, this vessel is blocked property in which CORNIOLA LIMITED and KRAPE MYRTLE CO LTD have an interest. It has been used to transport Venezuelan oil.

    ROSALIND

    AKAs: LUNAR TIDE

    • Vessel Type: Oil Products Tanker
    • Flag: Guinea
    • Vessel Year of Build: 2004
    • Vessel Registration Identification: IMO 9277735

    Linked to: WINKY INTERNATIONAL LIMITED

    The Treasury press release identifies this vessel as blocked property in which WINKY INTERNATIONAL LIMITEDhas an interest. It has been used to transport Venezuelan oil.

    VALIANT (VRXH3)

    • Vessel Type: Crude Oil Tanker
    • Flag: Hong Kong
    • Other Vessel Flag: China
    • Vessel Year of Build: 2009
    • Vessel Registration Identification: IMO 9409247
    • MMSI: 477206500

    Linked to: ARIES GLOBAL INVESTMENT LTD

    Based on the Treasury press release, this vessel is identified as blocked property in which ARIES GLOBAL INVESTMENT LTD has an interest.

    So, this was a result of trial and error – and asking Gemini what went wrong a few times. I learned the following things:

    • Originally, Gemini added “Linked to” data to the entities, linking them to the vessels that linked back to them. I had to add a line to the prompt to tell it to report what was actually in the listing and not infer Linked to data
    • WordPress sometimes does not play nicely with Gemini without manual intervention:
      • Hyperlinks sometimes will be preserved, and sometimes will get lost. However, they work just fine outside a standard paragraph – like, in a heading block.
      • Certain formatting, like bolding and italics, are preserved in a WordPress paragraph – centering is definitely not. Originally, Gemini gave me the <center></center> HTML tags around the text I wanted centered. I had a handful of options – center the text manually, give up on the centering, make the line into a header line or use a Custom HTML block.

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