Mr. Sanctions

Category: Venezuela

  • December 31, 2025: Closing out the OFAC year in Venezuela

    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 – Venezuela Sanctions

    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

    Linked to: DELLA; VALIANT

    Supplemental Information: According to the Treasury press release, Aries Global Investment Ltd is the registered owner of the vessel DELLA, which has transported Venezuelan oil. OFAC has designated this entity for operating in the oil sector of the Venezuelan economy. Additionally, the vessel VALIANT is identified as blocked property in which Aries Global Investment Ltd has an interest.

    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

    Linked to: NORD STAR

    Supplemental Information: According to the Treasury press release, Corniola Limited is the registered owner of the vessel NORD STAR, which has transported Venezuelan oil. OFAC has designated this entity for operating in the oil sector of the Venezuelan economy.

    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

    Linked to: NORD STAR

    Supplemental Information: According to the Treasury press release, Krape Myrtle Co Ltd is the ship manager and operator of the vessel NORD STAR. OFAC has designated this entity 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)

    Linked to: ROSALIND

    Supplemental Information: According to the Treasury press release, Winky International Limited is the registered owner of the vessel ROSALIND (a.k.a. LUNAR TIDE), which has transported Venezuelan oil. OFAC has designated this entity for operating in the oil sector of the Venezuelan economy.

    THE FOLLOWING VESSELS HAVE BEEN ADDED TO OFAC’S SDN LIST:

    VENEZUELA-EO13850 – Venezuela Sanctions

    DELLA

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

    Linked to: ARIES GLOBAL INVESTMENT LTD

    Supplemental Information: Identified by Treasury as blocked property in which Aries Global Investment Ltd has an interest. The vessel has been used to transport Venezuelan oil.

    NORD STAR

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

    Linked to: KRAPE MYRTLE CO LTD; Linked To: CORNIOLA LIMITED

    Supplemental Information: Identified by Treasury as blocked property in which Corniola Limited (registered owner) and Krape Myrtle Co Ltd (manager/operator) have an interest. The vessel has been used to transport Venezuelan oil and is described as part of the “shadow fleet.”

    ROSALIND

    AKAs: LUNAR TIDE

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

    Linked to: WINKY INTERNATIONAL LIMITED

    Supplemental Information: Identified by Treasury as blocked property in which Winky International Limited has an interest. The vessel has been used to transport Venezuelan oil.

    VALIANT

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

    Linked to: ARIES GLOBAL INVESTMENT LTD

    Supplemental Information: Identified by Treasury as blocked property in which Aries Global Investment Ltd has an interest.

    —

    , ,

  • Burning Question: A Primer on The “Shadow Fleet”

    An interesting sanctions topic, from a regulatory standpoint, but not so much from an operational standpoint – for all but the firms with the largest exposures (and with active documentary credit or marine insurance business lines), while they might leverage third party data, I highly doubt they will do the kind of active vessel tracking as listed below:

    While the term “shadow fleet” (often used interchangeably with “dark fleet”) is most frequently associated with Russia, Iran, and Venezuela, it does not refer to a formal navy belonging to any single nation. Instead, it is a decentralized, “stateless” network of aging merchant vessels—primarily oil tankers—that operate outside standard maritime regulations to evade international sanctions.

    Based on reports from late 2024 through 2025, here is the breakdown of the nations involved, how these vessels are identified, and by whom.

    1. Which Nations Have a “Shadow Fleet”?

    These three nations are the primary drivers of the shadow fleet, utilizing it to export sanctioned commodities (mostly crude oil, LNG, and refined products) to willing buyers in countries like China and India.

    • Russia: Currently operates the largest shadow fleet, estimated to include approximately 600–1,000 vessels. Following the G7 price cap on Russian oil, Moscow aggressively acquired aging tankers to bypass Western insurance and shipping services.
    • Iran: Has utilized a “ghost fleet” for decades to evade US sanctions. Their network is highly sophisticated, often specializing in ship-to-ship (STS) transfers in locations like the Strait of Malacca or the Persian Gulf to disguise the origin of their oil.
    • Venezuela: Relies on a similar, though often smaller and more dilapidated, fleet to export oil (primarily to Asia) in defiance of US sanctions on its state oil company, PDVSA.

    Note on Interconnectedness: Recent intelligence suggests these fleets are no longer distinct. They have evolved into an “interwoven” network where vessels may transport Russian oil on one voyage and Iranian or Venezuelan cargo on the next, sharing the same illicit maritime infrastructure and shell company networks.

    2. How Are They Identified?

    Identifying these vessels requires a “multi-sensor” approach because they actively employ deceptive shipping practices (DSP). Authorities and intelligence firms use a combination of the following methods:

    • AIS “Spoofing” Detection:
      • The Tactic: Vessels disable their Automatic Identification System (AIS) transponders (“going dark”) or use software to broadcast a fake location. For example, a ship physically loading oil in a Russian port may appear on digital maps to be sailing in the middle of the Atlantic.
      • The Counter-Measure: Analysts use algorithms to detect “AIS gaps” (periods of silence) or “impossible jumps” where a ship’s signal moves faster than physically possible.
    • Satellite Imagery & Remote Sensing:
      • Visual Confirmation: Optical satellites and Synthetic Aperture Radar (SAR) are used to “see” vessels through clouds and at night.
      • The Match: Analysts compare the satellite image of a vessel’s physical location against its broadcast AIS location. If a ship is seen via satellite at a restricted terminal while its AIS signal claims it is elsewhere, it is flagged as a spoofer.
    • Behavioral Analysis (The “Gray Fleet”):
      • Rather than hard evidence of a specific violation, analysts look for “abnormal” behaviors. This includes loitering in known trans-shipment zones (like the waters off Greece or Malaysia), frequent changes of ownership (often to shell companies in the UAE or Hong Kong), or “flag hopping” (frequently registering the ship in different high-risk jurisdictions).
    • Document & Insurance Verification:
      • Compliance officers check if a vessel has legitimate P&I (Protection and Indemnity) insurance from a reputable Western club. Shadow vessels often lack this or carry dubious insurance that would not provide coverage in the event of an oil spill.

    3. Who Identifies Them?

    The identification is a collaborative effort between government enforcers and private intelligence firms who sell their data to governments, banks, and traders.

    Government & International Bodies

    • OFAC (USA): The Office of Foreign Assets Control uses classified intelligence and public data to formally “designate” (sanction) specific vessels and their owners.
    • OFSI (UK) & European Commission: Similar to OFAC, these bodies track and list vessels banned from entering UK/EU ports or accessing maritime services.
    • The “Shadow Fleet Coalition”: A group of nations (including the UK, Denmark, Estonia, Finland, Poland, and Sweden) formed specifically to share intelligence on these vessels, particularly regarding environmental risks in the Baltic Sea.

    Private Sector & Intelligence Firms

    • Maritime AI Companies: Firms like Windward, Kpler, Vortexa, and Lloyd’s List Intelligence are the primary “detectives.” They use AI to process millions of data points and sell “risk alerts” to banks and insurers.
    • NGOs & Non-Profits: Organizations like Global Fishing Watch and SkyTruth use public satellite data to expose dark vessels, often focusing on environmental risks (e.g., oil spills from decrepit shadow tankers).
    • Academic Institutes: Think tanks like the Kyiv School of Economics (KSE) and RUSI (Royal United Services Institute) regularly publish detailed reports naming specific vessels and analyzing the fleet’s size.

    Summary of Key Identifiers (2024-2025 Context)

    IndicatorLegitimate FleetShadow / Dark Fleet
    OwnershipTransparent; known major shipping linesOpaque; shell companies in Seychelles, UAE, Hong Kong
    InsuranceInternational Group of P&I Clubs (High coverage)Unknown or “Shadow” insurers (Low/No coverage)
    Flag StateMarshall Islands, Liberia, Panama (Tier 1)Gabon, Cameroon, Cook Islands, Eswatini (High risk)
    AIS SignalAlways On; AccurateFrequently Off; Spoofed (Fake location)
    AgeTypically <15 yearsTypically >18-20 years (End of life)

    Sources

    • Atlantic Council (atlanticcouncil.org)
    • Brookings Institution (brookings.edu)
    • European Commission (finance.ec.europa.eu)
    • Global Fishing Watch (globalfishingwatch.org)
    • Kpler (kpler.com)
    • Kyiv School of Economics (KSE) (sanctions.kse.ua)
    • Lloyd’s List Intelligence (https://www.google.com/search?q=lloydslistintelligence.com)
    • Pole Star Global (polestarglobal.com)
    • Royal United Services Institute (RUSI) (rusi.org)
    • SkyFi (skyfi.com)
    • SkyTruth (skytruth.org)
    • U.S. Department of the Treasury (OFAC) (home.treasury.gov)
    • Ukrainian Defense Intelligence (war-sanctions.gur.gov.ua)
    • Windward AI (windward.ai)

    —

    , , ,

  • December 19, 2025: OFAC adds Maduro family & associates to SDN List, plus updated GL and FAQ

    Based on the OFAC Notice and related press releases for December 19, 2025:

    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:

    VENEZUELA-EO13850 Executive Order 13850

    CARRETERO NAPOLITANO, Roberto, Panama; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: CARRETERO NAPOLITANO, Ramon).

    CARRETERO NAPOLITANO, Vicente Luis, Panama; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: CARRETERO NAPOLITANO, Ramon).

    FLORES DE MALPICA, Eloisa, Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    HURTADO PEREZ, Damaris del Carmen, Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    MALPICA FLORES, Iriamni, Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    MALPICA HURTADO, Erica Patricia, Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    MALPICA TORREALBA, Carlos Evelio, Venezuela; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    Supplemental Information: The Treasury Department designated these seven individuals for their roles as family members and associates helping to sustain the narco-corruption structure of the Maduro regime. Specifically, the action targets the networks of Carlos Erik Malpica Flores (a nephew of Cilia Flores and former official at PDVSA and the Venezuelan Treasury) and Panamanian businessman Ramon Carretero Napolitano. Eloisa Flores de Malpica is the mother of Carlos Erik Malpica Flores and sister of Cilia Flores. Carlos Evelio Malpica Torrealba is his father, Iriamni Malpica Flores is his sister, Damaris del Carmen Hurtado Perez is his wife, and Erica Patricia Malpica Hurtado is his adult daughter. Roberto and Vicente Luis Carretero Napolitano are immediate family members of Ramon Carretero. Malpica Flores has been previously sanctioned and linked to corruption within Venezuela’s state-run oil company, PDVSA.

    You can learn more about the sanctions process in this video: OFAC Sanctions List Search tool which explains how to verify designated individuals.

    Additionally, we have a new version of GL 5:  Venezuela-related General License 5T, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After February 3, 2026.” As usual, the date at which you can deal in the bond has been pushed out – now it’s February 3rd of next year.

    And the related Frequently Asked Question – FAQ 595 – has been updated to reflect the new GL version and the new date.

    —

    , , , , ,

  • Yesterday’s OFAC update… now with designation updates

    The prompt is a work in progress, but I’m getting there…

    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

    Specially Designated Nationals List Update

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

    [ILLICIT-DRUGS-EO14059]

    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 (individual)

    Efrain Antonio Campo Flores is the nephew of Cilia Adela Flores de Maduro, the wife of Nicolas Maduro. Known as one of the “narco-nephews,” he was arrested in Haiti in November 2015 while finalizing a deal to smuggle cocaine into the United States. He was convicted in U.S. federal court but was granted clemency by President Biden in October 2022. According to the Treasury, since his return to Venezuela, he has resumed illicit drug trafficking activities.

    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 (individual)

    Franqui Francisco Flores de Freitas is the nephew of Cilia Adela Flores de Maduro. He was arrested alongside his cousin, Efrain Antonio Campo Flores, in Haiti in 2015 for conspiring to import cocaine into the United States. Following his conviction and subsequent clemency grant by President Biden in October 2022, he returned to Venezuela where, according to the Treasury, he continues to engage in narcotics trafficking.

    [VENEZUELA-EO13850]

    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 (individual)

    Ramon Carretero Napolitano is a Panamanian businessman designated for operating in the oil sector of the Venezuelan economy. He has secured contracts with the Government of Venezuela and maintains business ties with the Maduro-Flores family, including partnering with them in various companies. He is accused of facilitating the shipment of petroleum products for the regime.

    [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) (individual)

    Carlos Erik Malpica Flores is the nephew of Cilia Flores and previously served as the National Treasurer of Venezuela and Vice President of Finance for PDVSA. He was originally designated by OFAC in July 2017 but was delisted in 2022 to encourage political negotiations in Mexico City. Treasury has redesignated him for being an official of the Government of Venezuela.

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

    [VENEZUELA-EO13850]

    Blocking Property of Additional Persons Contributing to the Situation in Venezuela

    ARCTIC VOYAGER INCORPORATED

    AKAs: 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)

    Arctic Voyager Incorporated is the registered owner of the vessel KIARA M. The Treasury reports that this vessel loaded oil in Venezuela in September and October 2025 for transport to Asia.

    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)

    Full Happy Limited is the registered owner and commercial manager of the vessel MONIQUE. The vessel reportedly loaded and transported Venezuelan oil to Asia in late May 2025.

    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)

    Myra Marine Limited is the registered owner and commercial manager of the vessel WHITE CRANE. The vessel loaded oil in Venezuela as recently as October 2025 and utilized deceptive practices, such as obscuring its location, to hide its activities.

    POWEROY INVESTMENT LIMITED

    AKAs: POWEROY INVESTMENT LTD

    • Address: Virgin Islands, British
    • Identification Number: IMO 6438512

    Poweroy Investment Limited is the registered owner of the vessel H. CONSTANCE. The vessel reportedly loaded Venezuelan oil in October 2025 and manipulated its location transmissions.

    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)

    Ready Great Limited is the registered owner of the vessel LATTAFA. The vessel is accused of making multiple shipments of Venezuelan oil to Asia throughout 2025 while using deceptive tracking practices.

    SINO MARINE SERVICES LIMITED

    AKAs: 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)

    Sino Marine Services Limited is the ship manager and operator of the vessel TAMIA. The vessel reportedly loaded and transported Venezuelan oil to Asia in June 2025 while manipulating its location transmissions.

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

    [VENEZUELA-EO13850]

    Blocking Property of Additional Persons Contributing to the Situation in Venezuela

    H. CONSTANCE

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

    The H. CONSTANCE is a Panama-flagged crude oil tanker identified for loading Venezuelan oil in October 2025 and manipulating its transmissions to hide its location.

    KIARA M

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

    The KIARA M is a Panama-flagged crude oil tanker that loaded oil in Venezuela in September and October 2025, destined for Asia.

    LATTAFA

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

    The LATTAFA is a Panama-flagged crude oil tanker accused of transporting multiple shipments of Venezuelan oil to Asia in 2025 while obfuscating its movements.

    MONIQUE

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

    The MONIQUE is a Cook Islands-flagged crude oil tanker that loaded and transported Venezuelan oil to Asia in late May 2025.

    TAMIA

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

    The TAMIA is a Hong Kong-flagged crude oil tanker that loaded and transported Venezuelan oil to Asia in June 2025, using deceptive practices to hide its location.

    WHITE CRANE

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

    The WHITE CRANE is a Panama-flagged crude oil tanker that loaded oil in Venezuela in October 2025 and employed deceptive practices, such as failing to transmit its location, to hide its activities.

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

    [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

    AKAs: ADVANCED INFORMATION AND COMMUNICATION TECHNOLOGY RESEARCH INSTITUTE; AICTC; 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

    List of Changes:

    Field Name: a.k.a.

    Changed: “a.k.a. AICTC” to: “a.k.a. ADVANCED INFORMATION AND COMMUNICATION TECHNOLOGY RESEARCH INSTITUTE; a.k.a. AICTC; a.k.a. “AICT””

    RAHIMIAN, Pezhman

    AKAs: 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) (individual)Linked to: ATOMIC ENERGY ORGANIZATION OF IRAN

    List of Changes:

    Field Name: DOB

    Added: 29 Aug 1977

    —

    , , ,

  • December 11, 2025: Counter Narcotics Designations; Venezuela-related Designations; Non-Proliferation Designation Updates

    The following are the additions made from Counter Narcotics Designations; Venezuela-related Designations; Non-Proliferation Designation Updates (I have to find my prompt for updates) – and here is the Treasury Press Release “Treasury Targets Illegitimate Maduro Regime Insiders and Sanctions Evaders in Venezuela’s Oil Sector”

    Individuals

    [VENEZUELA-EO14059]

    • Definition: Executive Order 14059 of December 15, 2021, “Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade”.

    CAMPO FLORES, Efrain Antonio

    • Aliases: a.k.a. “Campo”; a.k.a. “Efraín Campo”; a.k.a. “Efraín Flores”
    • Nationality: Venezuela
    • DOB: [Approx. 1986]
    • Gender: Male
    • Type: Individual

    Supplemental Information: Efrain Antonio Campo Flores is the nephew of Cilia Flores, the wife of Nicolas Maduro. Known as one of the “Narco Nephews,” he was arrested in Port-au-Prince, Haiti, in November 2015 during a DEA sting operation while finalizing a deal to transport 800 kilograms of cocaine to the United States. He was convicted in the U.S. District Court for the Southern District of New York on narcotics trafficking charges in November 2016 and sentenced to 18 years in prison. In October 2022, he was granted clemency by President Joe Biden in a prisoner exchange for seven Americans detained in Venezuela. The Treasury Department states that since his return to Venezuela, he has continued his involvement in illicit drug trafficking activities.

    FLORES DE FREITAS, Franqui Francisco

    • Aliases: a.k.a. “Flores de Freitas”; a.k.a. “Franqui Flores”
    • Nationality: Venezuela
    • DOB: [Approx. 1985]
    • Gender: Male
    • Type: Individual

    Supplemental Information: Franqui Francisco Flores de Freitas is the nephew of Cilia Flores and cousin of Efrain Antonio Campo Flores. He was arrested alongside his cousin in Haiti in November 2015 for conspiring to smuggle cocaine into the U.S. and was convicted in New York in 2016, receiving an 18-year prison sentence. Like his cousin, he was granted clemency in October 2022 as part of a prisoner swap. The Treasury Department has designated him for continuing to engage in activities that contribute to the international proliferation of illicit drugs.

    [VENEZUELA-EO13692]

    • Definition: Executive Order 13692 of March 8, 2015, “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela”.

    MALPICA FLORES, Carlos Erik

    • Aliases: a.k.a. “Malpica”; a.k.a. “Malpica Flores, Carlos”
    • Address: Naguanagua, Carabobo, Venezuela
    • DOB: 17 Sep 1972
    • Nationality: Venezuela
    • Cedula No.: 11810943
    • Gender: Male
    • Type: Individual

    Supplemental Information: Carlos Erik Malpica Flores is another nephew of Cilia Flores. He formerly served as the National Treasurer of Venezuela and as the Vice President of Finance for the state-owned oil company, Petroleos de Venezuela, S.A. (PDVSA). He was previously designated by OFAC in July 2017 but was removed from the sanctions list in June 2022 by the Biden administration in an effort to encourage negotiations between the Maduro regime and the opposition. The Treasury Department has re-designated him for being a current or former official of the Government of Venezuela, citing the regime’s refusal to recognize democratic values.

    [VENEZUELA-EO13850]

    • Definition: Executive Order 13850 of November 1, 2018, “Blocking Property of Additional Persons Contributing to the Situation in Venezuela”.

    CARRETERO NAPOLITANO, Ramon

    • Aliases: a.k.a. “Carretero”
    • Nationality: Panama
    • DOB: 26 Nov 1990
    • POB: Ciudad de Panama, Panama
    • Gender: Male
    • Type: Individual

    Supplemental Information: Ramon Carretero Napolitano is a Panamanian businessman and former professional cyclist. He competed in the 2014 Giro d’Italia but was suspended from the sport in 2015 after testing positive for EPO. In the business world, he is accused of engaging in lucrative contracts with the Maduro regime and facilitating shipments of petroleum products on behalf of the Venezuelan government. He has partnered in several companies with the Maduro-Flores family. In September 2025, he reportedly survived a plane crash in Maiquetía, Venezuela, aboard a private jet (YV3440) linked to his business dealings.

    Entities

    [VENEZUELA-EO13850]

    • Definition: Executive Order 13850 of November 1, 2018, “Blocking Property of Additional Persons Contributing to the Situation in Venezuela”.

    ARCTIC VOYAGER INCORPORATED

    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands
    • Type: Entity
    • Linked To: KIARA M

    Supplemental Information: A Marshall Islands-registered company that is the registered owner of the Panama-flagged vessel Kiara M. The vessel loaded oil in Venezuela in September and October 2025 and transported it to Asia.

    FULL HAPPY LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands
    • Type: Entity
    • Linked To: MONIQUE

    Supplemental Information: A Marshall Islands-registered company that owns and manages the Cook Islands-flagged vessel Monique. The vessel loaded and transported Venezuelan oil to Asia in May 2025.

    MYRA MARINE LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands
    • Type: Entity
    • Linked To: WHITE CRANE

    Supplemental Information: A Marshall Islands-registered company that owns and manages the vessel White Crane. The vessel loaded oil in Venezuela as recently as October 2025 and has used deceptive shipping practices, such as manipulating its location transmissions.

    POWEROY INVESTMENT LIMITED

    • Address: Tortola, Virgin Islands, British
    • Type: Entity
    • Linked To: H. CONSTANCE

    Supplemental Information: A British Virgin Islands-registered company that owns the Panama-flagged vessel H. Constance. The vessel loaded Venezuelan oil in October 2025 and has repeatedly manipulated its AIS transmissions to hide its location.

    READY GREAT LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands
    • Type: Entity
    • Linked To: LATTAFA

    Supplemental Information: A Marshall Islands-registered company that owns the Panama-flagged vessel Lattafa. The vessel has made multiple shipments of Venezuelan oil to Asia throughout 2025 and has engaged in location obfuscation.

    SINO MARINE SERVICES LIMITED

    • Address: London, United Kingdom
    • Type: Entity
    • Linked To: TAMIA

    Supplemental Information: A UK-registered company that manages and operates the Hong Kong-flagged vessel Tamia. The vessel loaded and transported Venezuelan oil to Asia in June 2025 and has manipulated its transmissions to hide its activities.

    Vessels

    [VENEZUELA-EO13850]

    • Definition: Executive Order 13850 of November 1, 2018, “Blocking Property of Additional Persons Contributing to the Situation in Venezuela”.

    H. CONSTANCE

    • IMO: 9237773
    • Flag: Panama
    • Type: Vessel
    • Linked To: POWEROY INVESTMENT LIMITED

    Supplemental Information: An oil tanker identified as blocked property for transporting Venezuelan oil.

    KIARA M

    • IMO: 9285823
    • Flag: Panama
    • Type: Vessel
    • Linked To: ARCTIC VOYAGER INCORPORATED

    Supplemental Information: An oil tanker identified as blocked property for transporting Venezuelan oil.

    LATTAFA

    • IMO: 9245794
    • Flag: Panama
    • Type: Vessel
    • Linked To: READY GREAT LIMITED

    Supplemental Information: An oil tanker identified as blocked property for transporting Venezuelan oil.

    MONIQUE

    • IMO: 9311270
    • Flag: Cook Islands
    • Type: Vessel
    • Linked To: FULL HAPPY LIMITED

    Supplemental Information: An oil tanker identified as blocked property for transporting Venezuelan oil.

    TAMIA

    • IMO: 9315642
    • Flag: Hong Kong
    • Type: Vessel
    • Linked To: SINO MARINE SERVICES LIMITED

    Supplemental Information: An oil tanker identified as blocked property for transporting Venezuelan oil.

    WHITE CRANE

    • IMO: 9323429
    • Flag: Marshall Islands
    • Type: Vessel
    • Linked To: MYRA MARINE LIMITED

    Supplemental Information: An oil tanker identified as blocked property for transporting Venezuelan oil.

    The video below discusses the recent plane crash involving Ramon Carretero Napolitano, highlighting the “web of corruption” connecting him to the Maduro regime, which makes it relevant context for his designation.

    ACCIDENT IN VENEZUELA UNCOVERS CORRUPTION NETWORK

    —

    , ,

  • Burning Questions: Was that oil tanker seizure legal?

    So, I wanted to see what Gemini thought of yesterday’s activities… So I asked (notice the guardrails):

    Assuming all the allegations by the US Department of Defense and the Trump Administration are true, given all the published, in-force regulation, guidance, legislation and Frequently-Asked Questions, etc. published by the US government in relation to Venezuela and Iran, was yesterday’s seizure of an oil tanker off the coast of Venezuela legal? Justify your decision and produce sources from US government websites.

    and this is what I got back:

    Based on the reports of the seizure of the oil tanker “The Skipper” (formerly Adisa) on December 10, 2025, and assuming all allegations by the Department of Defense and the Trump Administration are true, the seizure is legal under United States law.

    The legality is grounded in a combination of Executive Orders (sanctions), federal statutes (forfeiture and anti-terrorism), and judicial process (seizure warrant).1

    Legal Justification

    1. Violation of Sanctions & Material Support to Terrorism2

    The US government alleges the tanker was transporting oil from Venezuela and Iran and supporting the Islamic Revolutionary Guard Corps (IRGC), which is designated as a Foreign Terrorist Organization (FTO).3

    • Iran Sanctions: Under the International Emergency Economic Powers Act (IEEPA) and Executive Order 13224 (Counter Terrorism), the US prohibits transactions that provide material support to designated terrorist organizations (like the IRGC).4 The transport of Iranian oil is considered a mechanism for funding the IRGC’s Qods Force.
    • Venezuela Sanctions: Executive Order 13850 and Executive Order 13884 block the property of Petróleos de Venezuela, S.A. (PdVSA) and prohibit US persons or those within US jurisdiction from dealing in Venezuelan oil.
    • Secondary Sanctions: Even for non-US ships, providing “material support” or goods/services to a designated FTO or sanctioned entity can trigger US jurisdiction under extraterritorial sanctions provisions.

    2. Civil Forfeiture Authority

    The seizure was reportedly conducted pursuant to a seizure warrant issued by a US federal court.

    • 18 U.S.C. § 981(a)(1)(C) and (G): These statutes authorize the civil forfeiture of any property, real or personal, which constitutes or is derived from proceeds traceable to a violation of IEEPA, or assets of any foreign terrorist organization engaged in planning or perpetrating acts of terrorism against the US.
    • Because the oil and the vessel constitute “property” used to facilitate these violations or are proceeds of the violations, they are subject to forfeiture to the US government.

    3. Maritime Law Enforcement

    • 14 U.S.C. § 522: This statute grants the US Coast Guard (which participated in the operation) the authority to make inquiries, examinations, inspections, searches, seizures, and arrests upon the high seas and waters over which the United States has jurisdiction, for the prevention, detection, and suppression of violations of laws of the United States.
    • Jurisdiction over the Vessel: While the vessel was reportedly “off the coast of Venezuela” (likely international waters), the US often establishes jurisdiction if:
      • The vessel is stateless (not properly registered).
      • The flag state (in this case, reportedly Guyana) consents to the US boarding and seizure.
      • The vessel is deemed “property” subject to a US court’s forfeiture warrant.

    Sources from US Government Websites

    • Authority for Sanctions (Iran & Counter-Terrorism):
    • Authority for Sanctions (Venezuela):
    • Forfeiture and Seizure Authority:
      • Asset Forfeiture Program (Department of Justice): Explains the use of forfeiture to disrupt criminal activity, including terrorist financing. Justice.gov – Asset Forfeiture Program
      • (Precedent) 2020 Seizure of Iranian Fuel: The Department of Justice previously successfully executed similar seizure warrants for Iranian fuel bound for Venezuela aboard the vessels Bella, Bering, Pandi, and Luna, citing the same legal authorities (IEEPA, forfeiture for FTO support).5 Justice.gov – 2020 Press Release

    And the list of sources included The Washington Post, the U.S. Department of Justice website, Al Jazeera and Wikipedia (for what that’s worth)…

    Would welcome someone more expert than me, and with no axe to grind, giving their opinion

    —

    , ,