Financial Integrity Monitor

Venezuela VE

Domains (D1–D6)

Sources

Role actions

Horizon <90d

Jurisdiction profile

Grey-ListTier ARisk: IncreasingPermissive

Venezuela remains on the FATF grey list under a CFATF-monitored action plan (high-level commitment June 2024); its 2022 CFATF MER found widespread technical and effectiveness deficiencies across BO transparency, FIU capacity, ML/TF prosecution, NPO oversight and TFS implementation.

The January 2026 capture of Nicolás Maduro and installation of Delcy Rodríguez has opened a rapid, still-unstable transition period marked by cascading OFAC general licenses reopening oil, gold/mineral and financial-services sectors, while state architecture enabling gold smuggling, dark-fleet oil evasion and TCO financing remains largely intact.

Key deficiencies

Beneficial ownership information not adequately, accurately or timely accessible
FIU resourcing and independence still developing despite recent reforms
Weak investigation/prosecution track record for ML and TF offences
NPO sector oversight assessed by FATF as disproportionate/non-risk-based, itself a TF-abuse-mitigation gap
TFS for TF and PF not implemented without delay
Legacy dark-fleet, gold-smuggling and shell-company infrastructure built under Maduro-era sanctions evasion persists structurally despite the leadership change

Recent developments (18m)

Nicolás Maduro captured by US forces in Operation Absolute Resolve (3 January 2026) and rendered to the US on narco-terrorism charges; Delcy Rodríguez sworn in as acting president
CFATF 3rd Enhanced Follow-Up Report (2025) re-rated several Recommendations, noting FIU independence/security improvements but persistent NPO and BO gaps
EU added Venezuela to its high-risk third-country AML/CFT list in June 2025 (Delegated Regulation amending 2016/1675)
Cascading OFAC general licenses (Feb-June 2026) reopening oil, gas, gold/minerals, financial-services and debt-restructuring transactions with the Government of Venezuela and PdVSA
State Department designation of Tren de Aragua as a Foreign Terrorist Organization/SDGT (February 2025) with multiple follow-on OFAC designations of members and a money-laundering network (December 2025)
Delaware court-ordered CITGO/PDV Holding auction concluded with Amber Energy (Elliott affiliate) winning bid (November 2025) to satisfy ~$20 billion in creditor judgments

Weekly brief

Lead signal

Lead Signal

Read full brief

Lead Signal

Venezuela's financial-integrity picture this cycle is dominated by a single, extraordinary sequence: OFAC's July 2025 designation of the Cartel de los Soles, headed by Nicolas Maduro Moros, as a Specially Designated Global Terrorist for providing material support to Tren de Aragua and the Sinaloa Cartel, followed by a State Department FTO designation, and culminating in the confirmed capture of Maduro by US forces on 3 January 2026 and his indictment on narco-terrorism, weapons, and narcotics charges in New York. Vice President Delcy Rodriguez was sworn in as interim president on 5 January 2026. This is architecture-over-incident at its most literal: a sanctions designation did not merely flag risk, it preceded and framed a head-of-state regime change.

Other Developments

A bifurcated sanctions posture. Even as the criminal case against the former regime proceeds at maximum pressure, OFAC has simultaneously issued a rapid cascade of general licenses -- GL46 through GL51 and lettered successors -- easing specific oil, diluent-supply, port and airport, electricity, and gold-related transactions under the Venezuela Sanctions Regulations, including GL 51 (6 March 2026) with mandatory chain-of-custody reporting. Core blocking sanctions and the underlying SDGT/FTO designations remain in force throughout. This is not policy incoherence; it is a genuinely mixed enforcement-and-enablement posture, and prose describing Venezuela's sanctions environment as simply "tightening" or simply "loosening" this cycle would understate the picture. Standing FATF grey-list status. FATF's 13 February 2026 statement retains Venezuela under increased monitoring, continuing to call for ensuring adequate, accurate, and up-to-date beneficial ownership information is accessible in a timely manner -- an unresolved deficiency that predates this cycle's political discontinuity and is not addressed by it. PDVSA's stablecoin dependency. PDVSA is reported to require USDT prepayment for spot oil deals since 2023-24, with an estimated 80% of oil revenue now settled in stablecoins via intermediary-routed Tron wallets; Tether froze $182 million across five such wallets on 11 January 2026. This finding's direction is credible but its scale sits on Tier 3/4 sourcing only, and the gate caps confidence at Assessed rather than High as a result. Supervisory continuity at risk. With Maduro captured and interim President Rodriguez installed, and sanctioned officials Diosdado Cabello and Vladimir Padrino reportedly retaining control of the security apparatus, institutional continuity of AML/CFT supervisors -- SUDEBAN, SUNEVAL, UNIF -- is uncertain heading into FATF's ongoing follow-up cycle, independent of whether the underlying statutory framework (the PNAP 2024-2026 national action plan) remains formally unchanged.

Cross-Monitor Connections

The narco-terrorism finance nexus underlying the Cartel de los Soles designation connects directly to conflict-finance analysis: narcotics-trafficking proceeds are alleged to fund, and be funded by, the same network Treasury now identifies as headed by the captured former president. The PDVSA-USDT settlement pattern and the Tether freeze sequence connect this cycle's financial-integrity findings to the crypto and world-payments consumers' parallel tracking of the same stablecoin rails and the same correspondent-banking general-license cascade -- three lenses on one underlying fact of state-scale financial infrastructure reorganising around sanctions pressure.

Outlook

The two variables most likely to move this picture next cycle are, first, whether OFAC's general-license cascade continues to expand or begins to contract as the interim government's posture toward US engagement becomes clearer, and second, whether SUDEBAN, SUNEVAL, and UNIF demonstrate functional continuity through the FATF follow-up process, or whether the transitional period produces a documented supervisory gap. The PNAP 2024-2026 action plan's mid-cycle review, expected in Q4 2026, will be an early test of the latter.

weekly_brief_draft · JID VE

Domain intelligence (D1–D6)

D1 Sanctions

Sanctions

Venezuela's sanctions picture this cycle is defined by a sequence that moved from designation to regime change with unusual speed. On 25 July 2025, OFAC designated the Cartel de los Soles as a Specially Designated Global Terrorist, naming Nicolas Maduro Moros as heading a group providing material support to Tren de Aragua and the Sinaloa Cartel; the State Department followed with an FTO designation effective 24 November 2025. On 3 January 2026, US forces captured Maduro, who now faces narco-terrorism, weapons, and narcotics charges in New York; Vice President Delcy Rodriguez was sworn in as interim president on 5 January 2026. This is a confirmed, Tier-1-sourced sequence and the single most consequential sanctions-architecture development affecting Venezuela in this or recent cycles.

What makes this cycle's picture genuinely mixed rather than simply escalatory is OFAC's parallel behaviour: even as the criminal case proceeds, the agency has issued a rapid cascade of general licenses -- GL46, GL47, GL48, GL46A/30B, GL49, GL50, and GL51 -- issued between January and March 2026, easing specific oil, diluent-supply, port and airport, electricity, and gold-related transactions under the Venezuela Sanctions Regulations. GL 51, issued 6 March 2026, carries mandatory chain-of-custody reporting. Core blocking sanctions under EO 13884 and the SDGT/FTO designations remain fully in force throughout this licensing activity. The architecture here is bifurcated by design: maximum-pressure criminal enforcement against individuals coexists with incremental commercial relief for specific transaction classes, and neither element should be read as diluting or negating the other.

For institutions with Venezuela exposure, the practical consequence is that screening obligations under the Cartel de los Soles SDGT designation and the broader EO 13224/13850 framework remain live and, if anything, sharpened by the head-of-state-level enforcement action, while specific licensed transaction corridors have simultaneously reopened. Both facts must be tracked together; treating the general-license cascade as a general loosening of Venezuela sanctions would misread the record.

Outlook

The trajectory to watch is whether the general-license cascade continues to expand as the interim government's relationship with Washington develops, or whether it stalls or reverses. Either direction would be a material development for institutions currently relying on GL46-51 to structure specific Venezuela-exposed transactions.

D2 Beneficial Ownership

Not covered

Beneficial Ownership is not yet covered for this jurisdiction in this report.

D3 Enabler Jurisdictions

Not covered

Enabler Jurisdictions is not yet covered for this jurisdiction in this report.

D4 Conflict Finance

Conflict Finance

Venezuela's conflict-finance picture this cycle is substantially the same underlying fact as its sanctions picture, viewed through a different lens: the Cartel de los Soles, now identified by US Treasury as headed by the captured former president Nicolas Maduro Moros, is alleged to have provided material support to Tren de Aragua and the Sinaloa Cartel, and narcotics-trafficking proceeds are alleged to fund, and be funded by, that same network. This is a confirmed, Tier-1-sourced finding, and it represents an unusually direct case of the conflict-finance and state-capture literatures converging on a single entity: the network implicated in narco-terrorism finance is, on Treasury's own designation, the same network that controlled the state itself until 3 January 2026.

This is architecture, not incident, in the FIM analytical sense: the designation names a structural criminal-financial network embedded in state institutions rather than a discrete transaction or episode. The overlap with sanctions architecture (D1) is substantial and should be read as one finding viewed twice rather than two independent developments -- the same OFAC action, the same designation, the same 25 July 2025 date, and the same underlying entity. What distinguishes the conflict-finance framing is the emphasis on the alleged narcotics-proceeds funding mechanism itself, rather than on the sanctions-compliance consequences of the designation.

No additional conflict-finance-specific development -- separate from the Cartel de los Soles nexus already described -- was evidenced this cycle. The gaps register for this cycle notes that no material new D3 enabler-jurisdiction finding surfaced either, with the dominant dynamic in Venezuela being domestic institutional capture rather than an external enabler-jurisdiction relationship; that absence is itself worth naming under the FIM principle that non-enforcement or non-finding in an otherwise heavily-covered jurisdiction can be analytically significant.

Outlook

Future cycles should watch for any additional detail on the scale and mechanics of the alleged narcotics-proceeds funding flows, which remain characterized only at the level of the designation itself rather than through transaction-level detail this cycle.

D5 Crypto / Digital Assets / Financial Innovation

Crypto / Digital Assets / Financial Innovation

Venezuela's crypto and digital-asset picture this cycle centres on one structurally significant, though weakly corroborated, finding: PDVSA is reported to require USDT prepayment for spot oil deals since 2023-24, with an estimated 80% of oil revenue now settled in stablecoins via intermediary-routed Tron blockchain wallets. Tether froze $182 million across five such wallets on 11 January 2026. This is assessed at Probable confidence, but the gate caps it there deliberately: all corroborating sources for the specific freeze amount and the settlement-share estimate are Tier 3/4 crypto-press material, with no Tier-1 or Tier-2 confirmation located this cycle.

The analytical significance of this finding, if directionally accurate, is substantial: it would represent a sanctions-evasion channel operating at state scale, using stablecoin rails specifically because they route around the correspondent-banking channels closed off by the underlying sanctions architecture (D1). This is exactly the kind of structural finding the FIM register is designed to surface ahead of enforcement volume -- a state-scale financial-innovation workaround for sanctions exposure, documented here at Probable rather than Confirmed confidence precisely because the underlying sourcing has not yet reached primary-authority quality.

The Tether freeze itself is worth reading independently of the settlement-scale claim: whatever the true proportion of PDVSA revenue running through USDT, the freeze event demonstrates that a private stablecoin issuer is actively monitoring and interdicting Venezuela-linked wallet activity at a scale material enough to warrant a $182 million action in a single event. That is evidence of active private-sector sanctions enforcement occurring in parallel with, and partially substituting for, the absence of any Venezuelan domestic crypto-integrity regulator capable of performing the equivalent function.

Outlook

The priority gap for future cycles is Tier-1 or Tier-2 corroboration of either the settlement-scale estimate or the wallet-ownership attribution behind the freeze. Until that corroboration exists, this finding should continue to be treated as a credible-but-unconfirmed structural risk rather than an established fact.

D6 Compliance Technology & Active Defence

Not covered

Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.

D7 AML/CTF Regime

AML/CTF Regime

Venezuela's formal AML/CFT architecture -- the PNAP 2024-2026 national action plan, developed under the CFATF's enhanced follow-up process, and administered by SUDEBAN, SUNEVAL, and UNIF -- remains nominally unchanged this cycle. The 3rd Enhanced Follow-up Report describes the PNAP as establishing a comprehensive institutional framework for AML/CFT/CPF policies, and FATF's 13 February 2026 statement continues to place Venezuela under increased monitoring pending resolution of outstanding strategic deficiencies, principally around beneficial-ownership information timeliness and accuracy.

What has changed is not the statutory framework itself but the political authority standing behind it. With Maduro captured on 3 January 2026 and interim President Delcy Rodriguez sworn in on 5 January 2026, and with sanctioned officials Diosdado Cabello and Vladimir Padrino reportedly retaining control of the security apparatus, the institutional continuity of SUDEBAN, SUNEVAL, and UNIF is genuinely uncertain going into FATF's ongoing follow-up cycle. This finding is assessed at Probable confidence and rests on Tier 3 sourcing for the specific personnel-continuity detail, though the direction is corroborated by the broader regime-discontinuity record at Tier 1.

This is precisely the kind of architecture-over-incident distinction the FIM register exists to draw: a formally unchanged statutory action plan sitting atop an acutely uncertain institutional foundation is a materially different risk picture than either a stable framework with stable institutions, or a framework undergoing active legislative reform. Neither the PNAP's 71 programmatic actions nor its Jan2025-Dec2026 deadlines have been formally revised, but the transitional government's capacity to execute against them is now the operative uncertainty, not the plan's content.

Outlook

The PNAP's mid-cycle review, expected in Q4 2026, is the concrete near-term marker to watch: whether it proceeds on schedule and with substantive content, or is delayed or thinned by the transition, will be the clearest available signal of whether Venezuela's AML/CFT institutional continuity has held.

Regulatory horizon

In Force Pending2026-Q4 · ±half_year

PNAP 2024-2026 mid-cycle review amid regime discontinuity

Institutional capacity to execute the AML/CFT action plan is now contingent on transitional-government continuity rather than the pre-January 2026 administration.

Source

1 dated · 4 pending date · baseline fim-2026-07-06

Role action cards

MLROHigh

Cartel de los Soles SDGT/FTO designation and Maduro's capture sharpen live PEP and correspondent-banking screening exposure tied to Venezuela.

The designation and subsequent capture mean any Venezuela-linked PEP or correspondent relationship screened against EO 13224/13850 and the Cartel de los Soles designation should be treated as an active, not historical, sanctions-nexus risk. Reportable-activity thresholds tied to Venezuela-origin funds warrant heightened scrutiny given the regime-discontinuity backdrop.

2 evidence refs

ComplianceHigh

OFAC's GL46-51 general-license cascade selectively reopens specific Venezuela transaction corridors while core sanctions and the FATF grey-list status remain unchanged.

Policy frameworks referencing a blanket Venezuela sanctions posture need updating to reflect the genuinely bifurcated picture: specific oil, diluent, port/airport, electricity, and gold transactions may now be permissible under GL46-51, but core blocking sanctions, the SDGT/FTO designations, and Venezuela's FATF increased-monitoring status are all unchanged.

2 evidence refs

LegalHigh

Maduro's indictment on narco-terrorism charges in New York establishes a live US criminal-enforcement nexus alongside the civil sanctions architecture.

Legal exposure analysis for Venezuela-linked matters must now account for both the sanctions-designation track (SDGT/FTO, EO 13224/13850) and the parallel criminal-prosecution track in the Southern District of New York, which together raise the liability stakes for any client instruction touching the Cartel de los Soles network or its alleged financial infrastructure.

2 evidence refs

BoardAssessed

Venezuela's regime discontinuity and the associated sanctions-architecture volatility represent material reputational and strategic exposure for institutions with any residual Venezuela nexus.

The combination of a captured and indicted former head of state, an active FTO/SDGT designation naming the deposed leadership, and a still-unsettled general-license cascade means Venezuela exposure carries reputational as well as compliance risk at the institutional level, warranting board-level visibility rather than delegation to compliance alone.

2 evidence refs

CTOAssessed

PDVSA's reported USDT-dominant oil-revenue settlement and Tether's $182m wallet freeze place Venezuela-linked stablecoin infrastructure inside active sanctions-enforcement scope.

Technical infrastructure with any exposure to Tron-network USDT flows touching Venezuela-linked wallets should be assessed against the demonstrated pattern of issuer-level freeze action; this is architecture risk at the level of the settlement rail itself, not merely a counterparty-screening question, though the specific scale figures remain Tier 3/4-sourced and should be treated as directionally credible rather than confirmed.

1 evidence refs

RiskHigh

Venezuela's risk profile has moved to increasing, with a mixed enforcement-versus-enablement posture and uncertain AML/CFT supervisory continuity through the transition.

Exposure-concentration models referencing Venezuela should reflect the jurisdiction_risk_tracker's assessment of increasing risk direction and mixed structural-versus-episodic character, driven by the combination of active narco-terrorism prosecution, cartel-linked designations, and the unresolved OFAC general-license sequence.

3 evidence refs

OperationsAssessed

GL46-51's chain-of-custody reporting requirement under GL 51 introduces a new operational screening and documentation step for any permitted Venezuela oil/gold-related transaction.

Transaction-monitoring workflows touching Venezuela-permitted corridors under the general-license cascade should incorporate the GL 51 mandatory chain-of-custody reporting requirement issued 6 March 2026, distinct from the broader sanctions screening already in place for blocked-party exposure.

1 evidence refs

AuditPossible

The PNAP 2024-2026 mid-cycle review, expected Q4 2026, is the concrete marker against which Venezuela's AML/CFT institutional-continuity claims should be tested.

Audit-trail adequacy for Venezuela-linked AML/CFT control testing should anchor to the PNAP's Q4 2026 mid-cycle review as a documented checkpoint, given that current supervisory-continuity uncertainty rests on Tier 3 sourcing rather than a confirmed institutional finding.

1 evidence refs

Decision lens

MLRO

Cartel de los Soles SDGT/FTO designation and Maduro's capture sharpen live PEP and correspondent-banking screening exposure tied to Venezuela.

Compliance

OFAC's GL46-51 general-license cascade selectively reopens specific Venezuela transaction corridors while core sanctions and the FATF grey-list status remain unchanged.

Legal

Maduro's indictment on narco-terrorism charges in New York establishes a live US criminal-enforcement nexus alongside the civil sanctions architecture.

Board

Venezuela's regime discontinuity and the associated sanctions-architecture volatility represent material reputational and strategic exposure for institutions with any residual Venezuela nexus.

CTO

PDVSA's reported USDT-dominant oil-revenue settlement and Tether's $182m wallet freeze place Venezuela-linked stablecoin infrastructure inside active sanctions-enforcement scope.

Risk

Venezuela's risk profile has moved to increasing, with a mixed enforcement-versus-enablement posture and uncertain AML/CFT supervisory continuity through the transition.

Operations

GL46-51's chain-of-custody reporting requirement under GL 51 introduces a new operational screening and documentation step for any permitted Venezuela oil/gold-related transaction.

Audit

The PNAP 2024-2026 mid-cycle review, expected Q4 2026, is the concrete marker against which Venezuela's AML/CFT institutional-continuity claims should be tested.

Shared evidence: 5 refs

Scenario sketches

Illustrative pathway: transitional-government AML/CFT institutional drift

Illustrative scenario for analytical orientation only. If Venezuela's transitional government proved unable to sustain SUDEBAN, SUNEVAL, and UNIF's supervisory functions through the FATF follow-up cycle, a plausible structural pathway would see AML/CFT enforcement capacity hollow out even without any formal amendment to the PNAP 2024-2026 action plan itself -- a scenario in which architecture and enforcement diverge, with the written framework persisting on paper while institutional execution degrades. This is illustration of a possible structural mechanism, not an observed fact or a prediction of Venezuela's actual trajectory.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Illustrative scenario: EU AML Package / AMLA supervisory transition

Illustrative scenario for analytical orientation only. As the EU AML Package matures, the shift from purely national AML supervision toward AMLA direct and indirect supervision of cross-border obliged entities, operating alongside the directly-applicable AMLR and per-state 6AMLD transposition, could plausibly reshape how evasion networks structured around non-EEA state-capture cases -- of the kind evidenced this cycle for Venezuela -- are detected when their proceeds transit EU-linked correspondent or crypto-exchange infrastructure. This is architecture-over-incident illustration of a structural possibility, not an observed fact or a prediction.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)

Tracker	Status	Note
T1 · Russian Sanctions-Evasion Architecture	no_change	No material Russia-linked dark-fleet or tech-procurement nexus specific to VE surfaced this cycle.
T2 · EU AML Package / AMLA	no_change	Not applicable — Venezuela is outside the EEA/EU perimeter.
T3 · FATF Grey List	watch	Venezuela remains under FATF increased monitoring per 13 February 2026 plenary statement, with seven outstanding action-plan items.
T4 · Beneficial-Ownership Register Status	watch	FATF's February 2026 statement continues to flag BO-information timeliness/accuracy as an unresolved deficiency for Venezuela.
T5 · Crypto & Digital-Asset Integrity	escalating	Tether's $182m five-wallet freeze and continued PDVSA USDT oil-revenue settlement mark this cycle's most consequential VE-specific crypto-integrity development.
T6 · Sanctions Regime Divergence	escalating	US sanctions posture on Venezuela has swung sharply (capture, indictment, rapid GL46-51 cascade) while EU/UK positioning has been comparatively static.

Registers

Enforcement actions

OFAC designated four Hong Kong/mainland China-based shell companies and four connected vessels (Della, Nord Star, Rosalind, Valiant) for evading Venezuelan oil-sector sanctions as part of an escalating pressure campaign against Maduro-regime oil exports. 31 Dec 2025
Following the February 2025 FTO/SDGT designation of Tren de Aragua, OFAC sanctioned top gang leaders (Hector 'Nino Guerrero' Guerrero Flores and others, July 2025) and, in December 2025, a broader money-laundering network including individuals and a Colombian entertainment-sector shell company supporting the group's finances. 3 Dec 2025
OFAC updated the SDN list on 1 April 2026 to remove Delcy Rodriguez as a Venezuela-program designation (reflecting her post-Maduro role as acting president), while separately maintaining/adding designations against Panama-based individuals (Roberto and Vicente Luis Carretero Napolitano) linked to Government of Venezuela asset concealment under the VENEZUELA-EO13850 program. 1 Apr 2026
CFATF's 3rd Enhanced Follow-Up Report (adopted with technical compliance re-ratings, reflecting progress to December 2025) assessed Venezuela's implementation of its Fourth Round MER recommended actions, finding some criteria met (e.g., Recommendation 2 national coordination) but continued deficiencies in beneficial ownership and NPO oversight. 1 Dec 2025
US special forces captured former President Nicolás Maduro and his wife in a raid (Operation Absolute Resolve) after prior narco-terrorism indictments, rendering him to the United States to face criminal charges including narcotics trafficking and corruption-linked financial crime allegations. 3 Jan 2026

Sanctions changes

Following Maduro's capture, OFAC issued a cascade of new Venezuela-related general licenses reopening oil/gas sector operations (GL 46C, 50B), gold/minerals trade (GL 51B, 54A, 55), financial-services transactions with Venezuelan banks and GoV individuals (GL 57), debt-restructuring services (GL 58) and contingent-contract negotiations for investment (GL 49A, 56), fundamentally restructuring the sanctions architecture from comprehensive blocking toward managed re-engagement. 10 Jun 2026
The EU Council renewed its Venezuela restrictive-measures regime (arms embargo, travel bans and asset freezes on 69 individuals) for a further year to 10 January 2027, maintaining the human-rights/rule-of-law-based sanctions architecture in place since November 2017 despite the change in Caracas leadership. 15 Dec 2025
The European Commission added Venezuela to its EU high-risk third-country AML/CFT delegated-regulation list in the June 2025 update, requiring EU-regulated entities to apply enhanced customer due diligence to Venezuela-linked transactions and relationships. 10 Jun 2025
OFAC removed Delcy Eloina Rodriguez Gomez from the Venezuela-program SDN list (1 April 2026), reflecting her transition from a sanctioned Maduro-regime official to the US-recognized transitional leadership counterpart following Maduro's capture. 1 Apr 2026

Regulatory horizon (register)

FATF October 2026 plenary review of Venezuela action plan
PdVSA 2020 8.5% bond GL 5X wind-down/CITGO-share litigation deadline
Venezuela PNAP 2024-2026 AML/CFT/CPF national action plan completion
EU Council review of Venezuela restrictive measures ahead of January 2027 expiry

Active schemes

[CRITICAL] Dark-fleet oil tanker network evading US crude sanctions
[CRITICAL] Conflict-linked gold smuggling via Orinoco Mining Arc
[HIGH] PDVSA stablecoin (USDT) settlement to bypass bank sanctions
[CRITICAL] Tren de Aragua transnational money-laundering network
[HIGH] Panama/Colon shell-company network for GoV asset concealment

Sources

Coverage gaps

Despite CFATF re-ratings on some technical-compliance criter…

Despite CFATF re-ratings on some technical-compliance criteria, Venezuela's FATF action plan flags persistent failure to ensure beneficial ownership information is adequate, accurate and accessible in a timely manner -- a foundational gap enabling shell-company layering by state and non-state actors alike.

Global Witness satellite monitoring found extensive oil-slic…

Global Witness satellite monitoring found extensive oil-slick pollution (over 10,400 km² detected in Lake Maracaibo alone since January 2025) and irregular-mining-driven deforestation in the Orinoco Mining Arc continuing to expand even as OFAC licenses reopen extractive-sector investment, with no domestic environmental or beneficial-ownership disclosure regime to accompany the reopening.

The abrupt, US-driven leadership transition (Maduro's captur…

The abrupt, US-driven leadership transition (Maduro's capture and Rodríguez's ascension) has produced no announced dismantling of the repressive state apparatus or the financial architecture that sustained sanctions evasion; UN human rights investigators reported 87 new politically motivated detentions since the capture despite roughly 100+ political-prisoner releases.

No public evidence was found in this research window of Vene…

No public evidence was found in this research window of Venezuela adopting or mandating RegTech/AI-driven transaction-monitoring or perpetual-KYC supervisory expectations for its banking or virtual-asset sectors; SUDEBAN's March 2025 resolution establishes baseline AML/CFT/CPF policy-setting authority but no forward-looking compliance-technology mandate was identified.

Evidence

Confidence-tiered claims

No structured claims published for this jurisdiction yet.