The Department of the Treasury’s Office of Foreign Assets Control has designated Venezuelan state-owned oil company Petroleos de Venezuela under Executive Order 13850 for operating in the oil sector of the Venezuelan economy.
As Venezuela’s state-owned oil company, PdVSA has long been a vehicle for corruption. A variety of schemes have been designed to embezzle billions of dollars from PdVSA for the personal gain of corrupt Venezuelan officials and businessmen. For example, a 2014 currency exchange scheme was designed to embezzle and launder around $600 million from PdVSA, money obtained through bribery and fraud. By May 2015, the conspiracy had allegedly doubled in amount to $1.2 billion embezzled from PdVSA.
Abraham Edgardo Ortega, a Venezuelan national who was PdVSA’s executive director of financial planning, pleaded guilty to one count of conspiracy to commit money laundering for his role in the billion-dollar international scheme to launder funds embezzled from PdVSA. In a separate case, U.S. prosecutors have alleged that, from 2011 to 2013, senior Government of Venezuela and PdVSA officials, including Nervis Villalobos, the former Venezuelan vice minister of energy; Rafael Reiter, who worked as PdVSA’s head of security and loss prevention; and Luis Carlos de Leon, a former official at a state-run electric company, sought bribes and kickbacks from vendors in exchange for helping them secure PdVSA contracts and gain priority over other vendors for outstanding invoices during its liquidity crisis.
The action designating PdVSA, announced by Treasury on Jan. 28, follows a determination by Secretary of the Treasury Steven Mnuchin pursuant to Executive Order 13850 that persons operating in the oil sector of the Venezuelan economy may be subject to sanctions. Concurrent with this action, OFAC is issuing general licenses that authorize certain transactions and activities related to PdVSA and its subsidiaries within specified timeframes. As a result of this action, all property and interests in property of PdVSA subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.