--- title: "Venezuela (VE) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/venezuela/ source_html: /jurisdictions/venezuela/index.html description: "Financial integrity intelligence for Venezuela (VE): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: ba3b206e5c8885435fc9df2e43664131f8be085189b9b0848a099ff359c33a42 generator: "fe-fleet/md-twin@1.0" --- # Venezuela (VE) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Venezuela VE Domains covered 8 of 8 Sources 195 Role actions 8 Horizon <90d 4 Jurisdiction profile FATF status: Grey-List Tier: A Risk direction: Increasing Enablement vs enforcement: Permissive 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. More 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 Brief ## Lead signal #### Lead Signal Venezuela's sanctions posture moved on two tracks this cycle without any structural change to the underlying US sanctions architecture. On 14 October 2026 OFAC removed Jorge Jesus Rodriguez Gomez from the SDN list under the Venezuela sanctions programme, with no public reason given for the delisting. Two days later, on 16 October 2026, OFAC amended General License 60 to General License 60A, extending the earthquake-relief authorisation first issued on 25 June 2026 and due to expire on 23 October 2026; the amended licence authorises earthquake-relief-related transactions including third-country fund transfers, with a reliance safe harbour for US financial institutions and registered money transmitters acting on originator representations. The US Federal Register published the underlying GL 60 text on 13 October 2026, formalising its public record. Read together, these are named, dated, time-bound adjustments rather than a general loosening: a single individual delisted, a single humanitarian carve-out extended. Venezuela otherwise remains on the FATF list of jurisdictions under increased monitoring, a status confirmed at the 19 June 2026 Plenary and carried forward in the absence of a located October 2026 plenary outcome. Read full brief #### Lead Signal Venezuela's sanctions posture moved on two tracks this cycle without any structural change to the underlying US sanctions architecture. On 14 October 2026 OFAC removed Jorge Jesus Rodriguez Gomez from the SDN list under the Venezuela sanctions programme, with no public reason given for the delisting. Two days later, on 16 October 2026, OFAC amended General License 60 to General License 60A, extending the earthquake-relief authorisation first issued on 25 June 2026 and due to expire on 23 October 2026; the amended licence authorises earthquake-relief-related transactions including third-country fund transfers, with a reliance safe harbour for US financial institutions and registered money transmitters acting on originator representations. The US Federal Register published the underlying GL 60 text on 13 October 2026, formalising its public record. Read together, these are named, dated, time-bound adjustments rather than a general loosening: a single individual delisted, a single humanitarian carve-out extended. Venezuela otherwise remains on the FATF list of jurisdictions under increased monitoring, a status confirmed at the 19 June 2026 Plenary and carried forward in the absence of a located October 2026 plenary outcome. #### Other Developments Conflict-finance enforcement continues against the Saab network. Alvaro Pulido Vargas, also known as German Rubio Salas, was arrested on 11 October 2026 on two federal indictments covering money laundering and bribery connected to alleged diversion of Maduro-government and PDVSA humanitarian-programme funds. Pulido is reported as an associate of previously sanctioned financier Alex Saab. The arrest was reported via a direct quote from a Deputy Attorney General carried by press coverage; the Department of Justice's own release on the matter was not independently retrieved this cycle, which caps the finding at a probable rather than confirmed tier. The crypto-regulatory posture remains unsettled. SUNACRIP, Venezuela's crypto regulator, remains in restructuring dating to the March 2023 PDVSA-Cripto scandal, and the National Assembly's Innovation Subcommittee continues technical consultations toward a new crypto law, with no bill yet filed. Two exchanges, Crixto and Kontigo, remain the known publicly licensed operators subject to AML/CFT/PF compliance as a condition of licensure. The standing AML/CTF regime is unchanged. Venezuela's framework continues to rest on the LOCDOFT statute with ONCDOFT as coordinating authority, a regime that GAFILAT and GAFIC mutual evaluation have assessed as institutionally weak; no development altering that assessment was identified this cycle. #### Cross-Monitor Connections The payments dimension of the General License 60A amendment connects directly to correspondent-banking and settlement-access questions: the licence's third-country fund-transfer authorisation and its reliance safe harbour for financial institutions and money transmitters bear on how humanitarian-related flows into Venezuela can move through the international banking system notwithstanding the broader sanctions programme. The Pulido arrest sits within a conflict-finance and state-capture pattern already associated with the Alex Saab network, relevant to any tracking of PDVSA-linked humanitarian-fund diversion. The unsettled SUNACRIP posture and the absence of a filed crypto law are relevant to any assessment of digital-asset-based sanctions-evasion exposure tied to Venezuela, given the jurisdiction's continued FATF grey-list status. #### Outlook General License 60A is due to lapse on 23 October 2026 absent further OFAC action; its renewal, lapse or further amendment is the near-term decision point to watch for continued humanitarian-channel payments access. Venezuela's FATF increased-monitoring status was last confirmed at the 19 June 2026 Plenary, and no October 2026 plenary outcome has yet been located, leaving that status to be read as carried forward rather than independently reconfirmed. The Pulido prosecution is at an early stage, with charges filed and an arrest made but no indication yet of trial or resolution; its progress will bear on the broader conflict-finance picture connected to the Saab network and PDVSA humanitarian-fund diversion allegations. Earlier periodic briefs (7) 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Venezuela's sanctions posture moved on two tracks without any structural change to the underlying US sanctions architecture. On 14 October 2026 OFAC removed Jorge Jesus Rodriguez Gomez from the SDN list under the Venezuela sanctions programme, with no public reason given for the delisting. Two days later, on 16 October 2026, OFAC amended General License 60 to General License 60A, extending the earthquake-relief authorisation first issued on 25 June 2026 and due to expire on 23 October 2026; the amended licence authorises earthquake-relief-related transactions including third-country fund transfers, with a reliance safe harbour for US financial institutions and registered money transmitters acting on originator representations. The US Federal Register published the underlying GL 60 text on 13 October 2026, formalising its public record. Read together, these are named, dated, time-bound adjustments rather than a general loosening: a single individual delisted, a single humanitarian carve-out extended. Venezuela otherwise remains on the FATF list of jurisdictions under increased monitoring, a status confirmed at the 19 June 2026 Plenary and carried forward in the absence of a located October 2026 plenary outcome. #### Other Developments Conflict-finance enforcement continues against the Saab network. Alvaro Pulido Vargas, also known as German Rubio Salas, was arrested on 11 October 2026 on two federal indictments covering money laundering and bribery connected to alleged diversion of Maduro-government and PDVSA humanitarian-programme funds. Pulido is reported as an associate of previously sanctioned financier Alex Saab. The arrest was reported via a direct quote from a Deputy Attorney General carried by press coverage; the Department of Justice's own release on the matter was not independently retrieved, which caps the finding at a probable rather than confirmed tier. The crypto-regulatory posture remains unsettled. SUNACRIP, Venezuela's crypto regulator, remains in restructuring dating to the March 2023 PDVSA-Cripto scandal, and the National Assembly's Innovation Subcommittee continues technical consultations toward a new crypto law, with no bill yet filed. Two exchanges, Crixto and Kontigo, remain the known publicly licensed operators subject to AML/CFT/PF compliance as a condition of licensure. The standing AML/CTF regime is unchanged. Venezuela's framework continues to rest on the LOCDOFT statute with ONCDOFT as coordinating authority, a regime that GAFILAT and GAFIC mutual evaluation have assessed as institutionally weak; no development altering that assessment was identified. #### Cross-Monitor Connections The payments dimension of the General License 60A amendment connects directly to correspondent-banking and settlement-access questions: the licence's third-country fund-transfer authorisation and its reliance safe harbour for financial institutions and money transmitters bear on how humanitarian-related flows into Venezuela can move through the international banking system notwithstanding the broader sanctions programme. The Pulido arrest sits within a conflict-finance and state-capture pattern already associated with the Alex Saab network, relevant to any tracking of PDVSA-linked humanitarian-fund diversion. The unsettled SUNACRIP posture and the absence of a filed crypto law are relevant to any assessment of digital-asset-based sanctions-evasion exposure tied to Venezuela, given the jurisdiction's continued FATF grey-list status. #### Outlook General License 60A is due to lapse on 23 October 2026 absent further OFAC action; its renewal, lapse or further amendment is the near-term decision point to watch for continued humanitarian-channel payments access. Venezuela's FATF increased-monitoring status was last confirmed at the 19 June 2026 Plenary, and no October 2026 plenary outcome has yet been located, leaving that status to be read as carried forward rather than independently reconfirmed. The Pulido prosecution is at an early stage, with charges filed and an arrest made but no indication yet of trial or resolution; its progress will bear on the broader conflict-finance picture connected to the Saab network and PDVSA humanitarian-fund diversion allegations. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal The defining development for Venezuela this cycle is the architecture-level liberalisation of US sanctions correspondent-banking access. OFAC General License No. 57 authorises financial-services transactions, account maintenance, card and ACH processing, and correspondent banking with Banco Central de Venezuela, Banco de Venezuela, Banco Digital de los Trabajadores and Banco del Tesoro, together with majority-owned affiliates and persons blocked solely by virtue of Government of Venezuela status. This is a categorical shift rather than an incremental carve-out: it restores correspondent access to the core of the state banking system that had been cut off, and it follows a sequence of general-licence amendments across the oil and investment programmes (GL46E, GL48D, GL49B) issued on 28 September 2026. The pattern since the January 2026 change of control in Caracas is a steadily widening US relief track, and it sits against a FATF status that has not moved: Venezuela remained on the FATF list of jurisdictions under increased monitoring as of the 19 June 2026 plenary, with no October 2026 plenary outcome yet published. #### Other Developments A bounded humanitarian channel sits alongside the architecture-level relief. OFAC General License No. 60 authorises earthquake-relief-related transactions and fund transfers via third-country persons through 23 October 2026, with the standard financial-institution reliance safe harbour attached to OFAC licences generally. Its defined expiry date makes the renewal-or-lapse decision the near-term structural signal to watch, distinct from the open-ended GL 57 relief. Reported sectoral AML supervision targeting non-financial enablers remains unconfirmed at primary-source level. Press reporting describes a planned Q4 2026 inspection programme by the Unidad Nacional de Inteligencia Financiera covering lawyers, notaries, accountants and real-estate firms under LOCDOFT, framed in two stages. The underlying UNIF circular has not been independently retrieved this cycle, so this is carried at an uncertain tier pending confirmation from the regulator itself. SUNACRIP continues to issue licences from a position of institutional degradation. The crypto-asset regulator has operated under an intervenor and restructuring board since the March 2023 PDVSA-Cripto scandal, with its former superintendent still detained, yet it renewed exchange licences for Crixto (through 31 December 2026) and Kontigo (through 8 January 2027) in 2026. No primary SUNACRIP instrument was retrieved this cycle to clarify what the intervention means in practice for the licensing perimeter. #### Cross-Monitor Connections The correspondent-banking relief under GL 57 and GL 60 is the same underlying sanctions-architecture fact that the world payments monitor is tracking as a settlement-access story, and the SUNACRIP licensing posture described above is the same institutional fact the crypto monitor is tracking as a licensing-perimeter story; both are read here through the AML/CTF and sanctions-evasion lens rather than re-derived. The widening gap between an accelerating US relief track and an unchanged EU renewal of autonomous human-rights sanctions to 10 January 2027 is itself a structural signal for correspondent banks and crypto counterparties assessing Venezuela exposure: a bank or exchange calibrated to a single sanctions regime risks misreading the overall posture if it does not track the divergence across blocs. #### Outlook Two dates anchor the near-term picture: the GL 60 humanitarian-licence expiry on 23 October 2026, and the next FATF plenary review of Venezuela grey-list status expected in Q4 2026. A renewal or broadening of GL 60 would extend the eased corridor for remittance and crypto on/off-ramp flows; a lapse would close it on schedule. A change in FATF status at the next plenary would update the de-risking calculus independently of whatever the US sanctions track does. Absent primary confirmation of the UNIF sectoral supervision plan or of SUNACRIP's post-intervention licensing authority, both remain watch items rather than confirmed structural developments. 4 Oct 2026 · fim-2026-10-04 #### Lead Signal The dominant financial-integrity signal on Venezuela this cycle is administrative rather than legislative: OFAC's Venezuela-Related Sanctions program index was re-stamped with a Program Last Updated marker of 28 September 2026, reflecting a run of General Licence amendments issued through the month rather than a new instrument. General Licence 5Z, issued 16 September 2026, further delays the effectiveness of General Licence 5 to 5 November 2026. General Licences 5X and 5Y were formalised in the Federal Register on 23 September 2026. General Licence 52C, dated 14 September 2026, narrows and expands PDVSA-contract signing authority within the sanctions program. None of these amendments touches the base executive-order architecture (EO 13692, 13808, 13827, 13850 and 13884), which remains formally in force. The result is a two-track regime: staged, broadening relief for US persons operating around Venezuelan state counterparties, running alongside an explicit, continuing bar on petro-denominated settlement that the licence series has not disturbed. This is a structural reading, not an incident: the substance of the US posture toward Venezuela is being written through licence-by-licence administration of an architecture that itself has not moved. Read against FATF's most recent plenary statement, of 19 June 2026, Venezuela remains under increased monitoring, with deficient and inaccessible beneficial-ownership information named as an open action-plan item. No subsequent plenary outcome was located inside this cycle's window; the next scheduled plenary falls around October 2026. The persistence of a grey-list designation alongside an active, moving US licensing track is itself a finding: enforcement posture and bilateral commercial accommodation are proceeding on separate, only loosely coordinated timelines. #### Other Developments A sentencing in Miami illustrates enabler-jurisdiction exposure inside the United States itself. Former US Congressman David Rivera was sentenced on 2 October 2026 to ten years imprisonment, with forfeiture of Florida real property, for covert, undisclosed lobbying conducted in 2017-2018 on behalf of Venezuela's PSUV government. The arrangement ran through a USD 50 million consulting contract tied to then-Foreign Minister Delcy Rodriguez, who now holds Venezuela's acting presidency. The case rests on quality-journalism reporting rather than a located primary Department of Justice release this cycle, and is carried at probable rather than confirmed confidence on that basis. Architecturally, the case is significant less for its individual facts than for what it demonstrates about enabler-jurisdiction analysis: the channel exploited for years was the United States' own political-consulting and lobbying infrastructure, not an offshore secrecy jurisdiction. An enabler-jurisdiction read of Venezuela-linked influence financing cannot stop at the periphery. The PDVSA-Cripto trial continues in Caracas with the regulatory vacuum it exposed still unfilled. Proceedings against more than fifty defendants tied to the 2023 collapse of the state crypto regulator SUNACRIP continued this cycle, with official loss estimates of USD 5.55 billion sitting against independent estimates running from USD 16.9 billion to USD 23 billion. No successor regulatory agency has been formally established. The claim rests on a single Tier 4 vendor source this cycle; no primary SUNACRIP or prosecutorial text was retrieved, and the finding is held at probable confidence accordingly. The persistence of the gap itself, nineteen months after the collapse it followed, is the structural point: an institutional void in digital-asset oversight has now outlasted the scandal that created it. #### Cross-Monitor Connections The sanctions-licence track intersects directly with the crypto monitor's cross-border-transfer findings: General Licence 52C's continuing exclusion of petro-denominated settlement, and General Licence 5Z's further delay of General Licence 5's effectiveness, are the same instruments that define the operative cross-border crypto corridor for Venezuela, meaning the US sanctions architecture functions as the de facto digital-asset settlement regime in the absence of a functioning domestic licensing authority. The PDVSA-Cripto trial's continuation without a successor regulator is similarly a shared finding across the sanctions and digital-asset lenses: a conflict-finance and extractive-industry integrity reading of the same institutional vacuum would ask what fills the supervisory space SUNACRIP vacated, a question this cycle's evidence base does not yet answer. The Rivera sentencing, while a US domestic criminal matter, routes naturally to any monitor tracking state-capture-adjacent influence financing, given the PSUV-government nexus and the acting-president connection. #### Outlook The near-term marker to watch is the FATF plenary expected around October 2026, which will either confirm Venezuela's continued increased-monitoring status or register movement on the beneficial-ownership deficiency flagged in June 2026. On the sanctions track, General Licence 5's delayed effectiveness date of 5 November 2026 is itself a date to track: a further delay would extend the current two-track pattern, while allowing the licence to take effect as scheduled would mark the first concrete narrowing of the staged-relief sequence seen since September. Absent a new primary instrument, expect continued administration-by-licence of the existing architecture rather than a change to the underlying EO framework. 29 Sep 2026 · fim-2026-09-28 #### Lead Signal The fastest unilateral sanctions-relief sequence against a FATF grey-listed jurisdiction in recent memory is unfolding in Venezuela. Following the January 2026 leadership transition, OFAC advanced through General Licenses 52 through 57, with GL 56 and GL 57 issued on 14 April 2026 permitting commercial contract negotiation with the Government of Venezuela and a wide range of financial services, including account services, payment processing, wire transfers and correspondent banking, with four named Venezuelan state banks: Banco Central de Venezuela, Banco de Venezuela, Banco Digital de los Trabajadores and Banco del Tesoro. AML and FinCEN obligations remain in force for any participating institution notwithstanding the relief. Contemporaneously, on 1 April 2026, OFAC removed acting President Delcy Rodriguez from the Specially Designated Nationals List, unblocking her assets and permitting US-person transactions with her. This sequencing, a formerly-sanctioned senior official delisted in close proximity to a US-facilitated leadership transition, is a pattern worth tracking on its own terms: it raises a structural question about how delisting decisions interact with the political process that produced the person being delisted, independent of whether the underlying transition is judged legitimate or not. #### Other Developments Sanctions-regime divergence widens. US unilateral sanctions relief, GL 52 through GL 57 issued between January and April 2026, is advancing far faster than any European Union or United Kingdom delisting action on Venezuela. This is a material widening of cross-bloc sanctions-regime divergence: financial institutions with EU or UK nexus face a materially different compliance posture toward Venezuelan counterparties than those operating solely under US jurisdiction, and that gap is now wider than at any point in the recent tracking history of this divergence. FATF grey-list status persists. Venezuela remained on the FATF Jurisdictions under Increased Monitoring list through the 19 June 2026 plenary statement, with no delisting or new call-for-action escalation identified. The FATF increased-monitoring designation sits in tension with the OFAC relief track: one architecture is loosening while the other is unchanged, and the two should not be read as a single coordinated signal. #### Cross-Monitor Connections The correspondent-banking channel opened by GL 57 is directly relevant to payment-system monitors tracking cross-border settlement access, since it is the first authorisation of its kind covering the four named Venezuelan state banks. The same development touches gambling-adjacent and other sector-specific monitors assessing Venezuela market access, insofar as any improvement in banking connectivity changes the financial plumbing available to operators in those sectors, even where sector-specific licensing itself is unchanged. The SDN delisting of a senior government official occurring alongside a leadership transition is a pattern relevant to state-capture-of-process tracking more broadly, beyond the sanctions architecture alone. #### Outlook Watch for whether the EU and UK begin to narrow the divergence opened by the US relief sequence, and whether OFAC issues further general licenses beyond GL 57 that would extend correspondent-banking or payment-processing authorisations further. The FATF grey-list status is unlikely to move before the next scheduled plenary review; any change there would be a separate and significant signal from the OFAC relief track. The degree to which participating financial institutions actually make use of the GL 57 channels, rather than the channels remaining nominally open but commercially unused, is also a signal worth tracking going into the next cycle. 22 Sep 2026 · fim-2026-09-14 #### 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. 28 Aug 2026 · fim-2026-08-21 #### Lead Signal OFAC's issuance of General Licenses 56 and 57 on 14 April 2026 marks the most consequential Venezuela-related sanctions development this cycle, and it is best read as architecture rather than incident. GL 57 authorises a broad suite of US financial services — account access, payment processing, wire transfer, correspondent banking, card and digital-payment services — with four named Venezuelan state banks (Banco Central de Venezuela, Banco de Venezuela, Banco Digital de los Trabajadores, and Banco del Tesoro) and certain government-affiliated individuals blocked solely under Executive Order 13884. GL 56 separately broadens authorisation to negotiate, though not yet perform, contingent commercial contracts with the Government of Venezuela across all sectors. Read together with the preceding GL 49 through GL 52 sequence since January 2026, this is a managed, incremental easing rather than a systemic lifting of sanctions: AML and FinCEN obligations remain fully in force, and GL 57 carries a reliance safe-harbor provision permitting processing institutions to rely on originator and beneficiary compliance representations absent actual knowledge of non-compliance. That structural design choice is itself the signal — it shifts the practical compliance burden downstream onto counterparty representations rather than removing screening obligations, and it is the kind of durable procedural architecture that outlasts any single general license. #### Other Developments Beneficial-ownership opacity persists despite formal supervisory action. Venezuela remains under FATF increased monitoring following the February 2026 plenary, with its seven-point action plan — spanning risk understanding, DNFBP/VASP supervision, beneficial-ownership timeliness, FIU resourcing, ML/TF prosecution, NPO safeguards, and targeted-sanctions implementation — still open. SUDEBAN Resolution No. 010.25 and SUNAVAL Resolution No. 025, both dated March 2025, formalise AML/CFT/CPF risk-management rule-making authority under the national PNAP 2024-2026 framework, but neither resolves the underlying beneficial-ownership timeliness deficiency that CFATF's follow-up process continues to flag. The persistence of this gap across a multi-year action-plan cycle, despite the 2025 supervisory resolutions, is consistent with a structural rather than a merely resource-driven deficiency in Venezuela's transparency architecture. Tether's record freeze surfaces stablecoin-issuer active defence against state-linked flows. On 11 January 2026, Tether froze approximately 182 million dollars across five Tron-network wallets — its largest single-day freeze to date — amid press and blockchain-analytics reporting linking the wallets to suspected Venezuelan oil-sanctions-evasion activity. Tether itself has not confirmed the Venezuela nexus, and the linkage rests on two independent Tier-3 sources rather than primary confirmation. Separately, PDVSA has reportedly required USDT for a significant share of oil-revenue settlement since 2023-2024, a practice that, if sustained, embeds a private stablecoin issuer's freezing capability as a de facto enforcement lever over state-linked oil-revenue flows outside any formal sanctions-designation process. #### Cross-Monitor Connections The correspondent-banking dimension of GL 57 is the shared spine between this brief and the World Payments Monitor's coverage of Venezuela's correspondent-banking and market-access modules, which track the same general-license text from the payments-infrastructure lens. The stablecoin freeze and PDVSA settlement finding connect directly to the Global Crypto Regulatory Monitor's cross-border-transfer and stablecoin-regime coverage of Venezuela, which examines the same Tether event and the same OFAC instrument from a digital-asset-market lens. The PDVSA oil-revenue settlement pattern also carries a latent conflict-finance and commodity-flow dimension — a state oil company routing revenue through an unregulated private stablecoin rail — that falls within the analytical remit of extractive-industry and commodity-flow monitoring even though it is not separately adjudicated as a standalone finding here. #### Outlook The next FATF/CFATF review window, expected in the fourth quarter of 2026, is the key date to watch: it may alter Venezuela's seven-point action-plan status, though assessors' progress reviews to date show no material remediation recognised on beneficial-ownership timeliness or FIU resourcing. Separately, whether GL 57's banking channel produces measurable transaction volume, and whether Tether's freeze proves durably linked to Venezuelan sanctions-evasion flows, are the two threads most likely to move next cycle's D1 and D5 assessments respectively. Absent confirmation, both remain open, not resolved, judgments. 11 Aug 2026 · fim-2026-08-05 #### Lead Signal The pivotal development this cycle is the cascading sequence of OFAC General Licenses affecting Venezuela, running from GL46 through GL60 across January to June 2026 and touching the oil, gold, and banking sectors. General License 57, effective 14 April 2026, is the structural high-water mark of the sequence: for the first time in seven years it authorizes financial-services transactions with the Banco Central de Venezuela and three state banks, covering account services, dollar transfers, correspondent banking, remittances, payroll and pension disbursement, digital wallets, and foreign-exchange market participation. A further supersession on 10 June 2026 replaced several of the earlier 2026 licenses, indicating that the license stack remains an actively managed instrument rather than a settled position. This is architecture, not incident: a structural reversal of the post-2017 comprehensive blocking regime rather than a single enforcement or relief action, and it sits alongside a persistent counter-signal — Venezuela remains on the FATF list of jurisdictions under increased monitoring following the 19 June 2026 plenary, which cited unresolved beneficial-ownership and financial-intelligence-unit capacity deficiencies. The overall jurisdiction-risk trajectory for Venezuela is accordingly best read as decreasing but mixed: the net signal blends genuine sanctions-relief liberalisation against AML/CFT institutional capacity that has not kept pace, an assessment that treats enforcement and enablement as running on separate clocks rather than converging toward a single direction. #### Other Developments The Organic Hydrocarbons Law Reform , enacted 29 January 2026, repeals nationalization-era statutes and cuts the mandatory joint-venture stake of PDVSA from sixty percent to fifty point one percent. The reform is corroborated across multiple law-firm advisories, though no Tier-1 or Tier-2 primary gazette text was retrieved this cycle, capping confidence at Assessed. The change reshapes oil-revenue governance at a moment when the broader sanctions architecture is simultaneously loosening, raising the structural question of who captures the upside as foreign capital re-enters the sector. The crypto-payments vacuum left by the paralysis of SUNACRIP is deepening rather than closing. The regulator has been non-functional since a March 2023 corruption purge, and the Petro cryptocurrency of Venezuela was formally terminated in January 2024. Into that vacuum, Binance P2P added Banco de Venezuela, Banco del Tesoro, and Banco Digital de los Trabajadores as payment methods following the GL57 easing, consolidating USDT and Binance P2P as the de facto dollar-settlement rail for a market with no operating crypto regulator. This is an enablement signal as much as a risk signal: the absence of enforcement here is itself analytically significant, since it means the channel is scaling without an active supervisory counterpart. The border response of Colombia and the standing Black Market Peso Exchange corridor round out the cycle. Colombia mobilized security forces along its border with Venezuela on 3 January 2026 following US strikes inside Venezuela, an episodic event layered atop a structural trade-based money-laundering corridor that routes narcotics-sale dollars through Colombian brokers into bolivars at the CENCOEX rate, with onward movement through Margarita Island and the Panama and Ecuador free-trade zones. The underlying typology is corroborated by archived Tier-1 US State Department reporting; the border-mobilization event itself carries an aggregator-only, Assessed-confidence sourcing profile. #### Cross-Monitor Connections The Hydrocarbons Law Reform is a direct feed to any commodity-flows or extractive-industry monitor tracking PDVSA governance and foreign-investment terms, since a reduced mandatory state stake changes who is exposed to Venezuelan oil-revenue integrity risk going forward. The GL46-GL60 sequence and the prospective BCV reincorporation into international payment rails are the natural feed to a payments-monitor reading of correspondent-banking access, where the binding constraint is understood to be correspondent-bank risk appetite rather than remaining OFAC restriction. The Colombia border-security response and the Black Market Peso Exchange corridor are conflict-finance and state-capture-adjacent signals: a militarized border layered on a standing trade-based laundering corridor is exactly the kind of structural condition that a conflict-finance or state-capture monitor would want flagged even in the absence of a discrete enforcement event this cycle. #### Outlook The clearest forward marker is the stated intention of FATF to conduct an on-site verification visit at the earliest availability for Venezuela, which under a successful outcome could open a path toward grey-list exit; absent that, the AML/CFT capacity deficiency of the jurisdiction will continue to sit uncomfortably alongside an improving sanctions picture. Watch also for further iteration of the OFAC license stack — the 10 June 2026 supersession pattern suggests this is not yet a settled architecture — and for whether international correspondent banks translate the permission of GL57 into actual relationship-building, which the evidence available this cycle frames as the real bottleneck rather than any remaining regulatory prohibition. The widening gap between US sanctions policy and the absence of an equivalent EU or UK relief sequence is itself a signal worth tracking, since divergent sanctions postures among major financial centres create exactly the kind of arbitrage conditions that correspondent-banking compliance teams need to monitor going into the next cycle. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion Venezuela's sanctions picture this cycle is defined by managed, named and time-bound adjustment rather than structural change. OFAC removed Jorge Jesus Rodriguez Gomez from the SDN list on 14 October 2026 under the Venezuela sanctions programme, with no public reason stated for the delisting. Separately, on 16 October 2026, OFAC amended General License 60 to General License 60A, extending the earthquake-relief authorisation first issued 25 June 2026 and originally due to expire 23 October 2026. The amended licence authorises earthquake-relief-related transactions in Venezuela, including third-country fund transfer and processing activity, and extends a reliance safe harbour to US financial institutions and registered money transmitters acting on originator representations. The US Federal Register published the underlying GL 60 text on 13 October 2026, formalising the public record ahead of the amendment. Venezuela remains on the FATF list of jurisdictions under increased monitoring, a status confirmed at the 19 June 2026 Plenary; no October 2026 plenary outcome has been located, so that status is carried forward rather than independently reconfirmed this cycle. Read architecturally rather than as a single event, the pattern is one of the sanctioning authority preserving the comprehensive designation regime for the government and state entities while carving out narrow, humanitarian-justified and individually named relief. Several hundred Venezuela-programme SDN entries remain listed notwithstanding the Rodriguez delisting and the GL60A extension, and neither action touches the broader architecture of designations against PDVSA-linked and government-linked entities. For firms screening Venezuela exposure, the practical implication is that the SDN list itself requires continuous re-screening given individual delistings, and any reliance on GL 60A for third-country humanitarian transfers should be read against its original 23 October 2026 expiry absent further amendment. Continue reading #### Outlook The near-term decision point is whether OFAC further extends, allows to lapse, or re-amends General License 60A beyond its original 23 October 2026 window; absent action, the earthquake-relief authorisation reverts to the default prohibition. Venezuela's FATF increased-monitoring status should be watched for a dated update at the next located plenary, since no October 2026 outcome has yet been confirmed. The Rodriguez delisting is sufficiently narrow and unexplained that it does not by itself signal a broader sanctions-relief trajectory; it should be read alongside, not instead of, the continued scale of the underlying SDN list. Judgment: US sanctions relief continues to advance unilaterally via designation removal and general-licence extension, while EU/UK autonomous positions remain unmoved, widening existing divergence. Probable #### Beneficial Ownership and Corporate Transparency Venezuela beneficial-ownership opacity remains the foundational, unresolved deficiency underpinning nearly every scheme this cycle documents. CFATF third Enhanced Follow-Up Report, published December 2025, upgraded select technical-compliance ratings, including Recommendation 2 on national coordination, but confirmed that beneficial-ownership information is still not adequately, accurately or timely accessible. This is a cumulative gap carried across successive CFATF follow-up cycles rather than a new finding, and it is foundational to the enabler-architecture thesis running through this brief: the Panama, Hong Kong and Colombian shell-company structures documented in OFAC designations this cycle depend directly on the absence of accessible beneficial-ownership data at the point of registration. Venezuela remains under FATF increased monitoring, a status confirmed at both the February and June 2026 plenaries, tracing to a June 2024 high-level commitment; the persistence of this status across two consecutive plenary cycles corroborates, rather than merely restates, the grey-list finding. Continue reading The European Commission June 2025 delegated-regulation update separately added Venezuela to the EU AML/CFT high-risk third-country list, a distinct instrument from FATF grey-listing that requires EU-regulated entities to apply enhanced due diligence to Venezuela-linked transactions and relationships. The CITGO and PdVSA-share litigation track also carries a beneficial-ownership and corporate-structure dimension: the November 2025 Delaware auction concluding with Amber Energy, an Elliott affiliate, as winning bidder to satisfy approximately USD 20 billion in creditor judgments, involved competing claims over layered corporate ownership of PdVSA-linked assets, a reminder that transparency deficiencies affect commercial litigation exposure as well as sanctions-evasion typologies. Standing architecture note: independent of any single cycle development, the EU AML Package rests on three distinct instruments that should be read as the durable backdrop against which Venezuela-linked beneficial-ownership signal is assessed. The AML Regulation, Regulation (EU) 2024/1624, is directly applicable across Member States without transposition. The sixth AML Directive, transposed individually by each Member State, sits alongside it. And the AMLA Regulation, Regulation (EU) 2024/1620, establishes the Anti-Money Laundering Authority and a direct and indirect supervision perimeter that shifts obliged-entity supervision from a purely national model toward a hybrid EU-level regime. Venezuela sits outside this perimeter as a non-EU third country, and its relevant touchpoint remains the high-risk third-country delegated-regulation listing rather than direct AMLA supervision; as AMLA matures toward its 2028 direct-supervision remit, Venezuela high-risk-third-country status is likely to become a standing input to AMLA own forthcoming third-country risk methodology, though this projection is not itself a finding of this cycle research. #### Outlook The FATF October 2026 plenary will test whether the transitional government under Rodriguez can deliver institutional reform, including beneficial-ownership measures, sufficient to move Venezuela toward delisting, while Venezuela national PNAP 2024-2026 action plan reaches nominal completion in December 2026, a concrete effectiveness marker for CFATF follow-up. Whether the persistent beneficial-ownership accessibility gap can close within a transitional-government timeframe, given that it has survived multiple prior CFATF follow-up cycles under the prior government, is an open question this cycle cannot resolve. This is illustrative orientation, not a prediction. Judgment: No public searchable beneficial-ownership register exists for Venezuela; standing position persists. Uncertain #### Enabler Jurisdictions and Professional Facilitators Panama-registered corporate-service providers continue to function as the primary professional-enablement layer for Venezuelan elite asset concealment, structurally independent of the leadership transition in Caracas. OFAC designated Roberto and Vicente Luis Carretero Napolitano on 19 December 2025 under the VENEZUELA-EO13850 program for facilitating Government of Venezuela asset concealment through Panama-based shell entities, a date corrected this cycle from an earlier erroneous 1 April 2026 attribution that had been bundled with a separate, now-retracted claim. This designation continues a documented pattern in which Panama corporate-service ecosystem provides nominee and shell-entity infrastructure that OFAC designations have repeatedly identified holding blocked Government of Venezuela-linked assets. Continue reading The dark-fleet evasion architecture depends on a parallel enabler layer: Hong Kong and mainland China-based trading shells anchored four of the shell companies OFAC designated on 31 December 2025 for evading Venezuelan oil-sector sanctions, underscoring the continuing role of Chinese-domiciled corporate structures in sustaining sanctions-evasion trade flows independent of any single enforcement wave. This is a four-dimension enabler-jurisdiction assessment worth stating explicitly: legal framework, enforcement posture, capacity versus choice, and systemic significance all point toward these structures functioning as durable infrastructure rather than opportunistic, one-off arrangements. Jurisdiction-agnostic assessment also applies to the EU and UK sides of this domain. The European Commission June 2025 delegated-regulation update added Venezuela to the EU AML/CFT high-risk third-country list, requiring EU-regulated entities to apply enhanced due diligence to Venezuela-linked transactions and relationships, a structural finding about EU regulatory perimeter rather than an enforcement action. Venezuela treatment as a UK high-risk third country is inferred from the HM Treasury FATF-mirroring Money Laundering Advisory Notice mechanism, but this specific application was not independently verified against a dated primary UK source this cycle, and should be treated as an analytically sound but unconfirmed inference pending direct verification rather than a settled fact. The persistent beneficial-ownership accessibility gap, confirmed by CFATF third Enhanced Follow-Up Report in December 2025 despite other technical re-ratings, is the structural condition that allows the Panama and Hong Kong enabler layers to function; absent that structural transparency deficiency, the layering documented in these OFAC designations would be substantially harder to sustain. #### Outlook Whether Panama or Hong Kong-domiciled corporate-service ecosystems face any enforcement or regulatory tightening as a consequence of continued OFAC designation activity is not established by this cycle evidence. The EU Council pre-expiry review of the Venezuela sanctions regime, scheduled for December 2026 ahead of the January 2027 expiry, may indirectly affect EU-side enhanced-due-diligence obligations on Venezuela-nexus relationships routed through these enabler jurisdictions. This is illustrative orientation, not a prediction. Judgment: ONCDOFT's September circular sequence (002-2026 expanding, then 003-2026 narrowing) AML registration for independent lawyers remains the latest standing development, raising professional-secrecy tension, though dated outside this window. Probable #### Conflict Finance and Extractive-Industry Integrity The conflict-finance signal this cycle is the arrest of Alvaro Pulido Vargas, also known as German Rubio Salas, on 11 October 2026, on two federal indictments covering money laundering and bribery tied to alleged diversion of Maduro-government and PDVSA humanitarian-programme funds. Pulido is reported as an associate of Alex Saab, the previously sanctioned financier whose network has been the subject of extended US enforcement attention concerning Venezuelan state-linked fund diversion. The arrest was reported through a direct quote attributed to a Deputy Attorney General and carried by press coverage; the Department of Justice's own release was not independently retrieved this cycle, which caps confidence in the specifics of the charges at a probable rather than confirmed tier. Read architecturally, the arrest continues a documented pattern in which humanitarian and state-linked financial flows connected to PDVSA have been a recurring vector for alleged diversion and laundering, with the Saab network as the through-line connecting this arrest to prior, more fully substantiated enforcement actions. The extractive-industry dimension of Venezuela's conflict-finance exposure remains anchored in PDVSA's centrality to both the country's oil revenue and the alleged diversion schemes now subject to prosecution; this arrest does not itself introduce a new extractive-sector mechanism but reinforces the existing one. No parallel civil forfeiture, asset-freezing or extraterritorial seizure action tied to this arrest was identified this cycle. Continue reading #### Outlook The Pulido prosecution is at an early stage: an arrest and indictment have occurred, but no trial date, plea, or resolution has been reported. Its progression is the item to watch, both for what further detail a DOJ release (not yet independently retrieved) might add to the current probable-confidence picture, and for whether the prosecution surfaces additional names within the broader Saab-linked network. The continued centrality of PDVSA-linked humanitarian-fund flows to this pattern means any further designation, indictment or asset action naming PDVSA-adjacent entities should be read against this same conflict-finance architecture rather than as an isolated event. Judgment: No new conflict-finance signal for Venezuela this cycle. Uncertain #### Crypto, Digital Assets, and Financial Innovation PDVSA mandated USDT stablecoin settlement for oil-trade contracts stands as the principal state-level crypto-integrity exposure in the Venezuela file. Facing correspondent-banking blockage from OFAC sanctions, PDVSA and its intermediaries reportedly required buyers of Venezuelan oil to settle contracts in USDT rather than dollar wires by early 2024, a practice that press reporting from that period indicates had become standard PDVSA contractual practice. This is corroborated by a 2022 DOJ indictment charging Venezuelan and Russian nationals with USDT-settled PDVSA oil smuggling to Russia and China, giving the stablecoin-settlement scheme both a documented enforcement history and continuing contemporaneous relevance. Applying a sanctions-architecture filter to this channel: the scheme functions at the transaction level as a bank-wire substitute, at the architecture level as a systemic sanctions-circumvention rail for an entire state oil enterprise, and at the strategic-consequence level as a template that other sanctioned state actors could observe and adapt. Continue reading No VASP registration or licensing regime, and no DeFi-specific enforcement engagement, was identified for Venezuela this cycle. This absence-of-evidence finding is itself analytically significant: a jurisdiction operating a state-level stablecoin-settlement sanctions-evasion channel with no accompanying virtual-asset-service-provider supervisory framework represents an enablement gap, whether by capacity constraint or by deliberate policy choice, that this cycle evidence cannot fully distinguish between. #### Outlook Whether the transitional government under Rodriguez introduces any VASP licensing or oversight framework, or whether the USDT-settlement channel continues unregulated as broader sanctions relief reopens correspondent-banking access, is not established by this cycle evidence. If correspondent-banking channels reopen more fully under the general-license cascade, the continuing operational rationale for USDT settlement may diminish, though this is an illustrative scenario rather than a prediction of any specific outcome. Judgment: Binance's bolívar on-ramp via a regulated casa de cambio continues the pattern of informal fiat-to-crypto access outside SUNACRIP's thin licensed-exchange perimeter. Probable #### Compliance Technology and Active Defence No evidence was identified this cycle of Venezuela adopting RegTech, AI-driven transaction monitoring, or perpetual-KYC supervisory expectations. SUDEBAN March 2025 resolution sets baseline AML/CFT/CPF policy-setting authority only, and no forward-looking compliance-technology mandate was located within the research window. This is an absence-of-evidence finding rather than a confirmed negative, and it is elevated in significance precisely because sanctions relief is simultaneously reopening cross-border financial flows: a supervisory-technology vacuum at the point where correspondent-banking, trade-finance and oil-sector engagement are all expanding compounds near-term money-laundering and terrorist-financing exposure rather than merely persisting neutrally. Continue reading This domain is marked as thin signal for this cycle honestly rather than padded: no domestic RegTech, transaction-monitoring modernisation, or supervisory-technology development for Venezuela was located in the evidence gathered, and the gap is carried forward as a persistent structural finding rather than a resolved or newly discovered one. #### Outlook Whether SUDEBAN or the transitional government introduces any forward-looking compliance-technology mandate as cross-border flows reopen is not indicated by current evidence. A dedicated SUDEBAN or national financial-intelligence-unit technology-supervision circular, if one exists, would close this gap; none was located this cycle. This is illustrative orientation, not a prediction. Judgment: No RegTech/compliance-technology development found for Venezuela this cycle. Uncertain #### 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. Continue reading 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. Judgment: Venezuela's AML/CTF regime still rests on the 2012 LOCDOFT, with ONCDOFT as rector body and UNIF as the FIU; no change to the standing regime description found this cycle. Probable Judgment: No commercial transaction among integrity-infrastructure firms found for Venezuela this cycle. Uncertain Regulatory horizon Proposed 2026-10 · ±quarter ### FATF October 2026 plenary review of VE grey-list status A removal or retention decision at the next FATF plenary would update VE's de-risking profile. [Source](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) Proposed 2026-Q4 · ±half_year ### Venezuela electricity-sector regulatory overhaul Would extend the foreign-investment-friendly reform campaign (hydrocarbons, mining) to the electricity sector. [Source](https://www.clearytradewatch.com/2026/07/venezuelas-oil-reform-efforts-new-opportunities-unanswered-questions-u-s-investor-perspective/) In Force Pending 2026-Q4 · ±quarter ### PNAP 2024-2026 biannual review / next FATF plenary review of Venezuela's action plan The next FATF/CFATF review window may alter Venezuela's seven-point action-plan status. [FATF / CFATF / ONCDOFT (Venezuela) Source](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) In Force Pending 2026-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. [Government of Venezuela / CFATF Source](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/CFATF-FUR-Venezuela-2025.pdf.coredownload.inline.pdf) 4 dated · 4 pending date · baseline fim-2026-07-06 Role action cards MLRO ### OFAC delisted Jorge Rodriguez and amended the Venezuela earthquake-relief general licence to GL60A this period. Continuous re-screening against the SDN list is required given the Rodriguez delisting, and any reliance on GL 60A for earthquake-relief-related third-country transfers should be checked against its original 23 October 2026 expiry absent further OFAC amendment. 2 evidence refs Compliance ### General License 60A extends a reliance safe harbour for institutions and money transmitters processing Venezuela earthquake-relief transactions. Institutions relying on the GL60A safe harbour on originator representations should track its 23 October 2026 expiry point and the absence, so far, of a further OFAC amendment. 1 evidence refs Legal ### A Saab-network associate, Alvaro Pulido Vargas, was arrested on federal money-laundering and bribery indictments tied to PDVSA humanitarian-fund diversion allegations. The prosecution is at an early stage with charges filed via indictment but no independently retrieved DOJ release, capping confidence at probable; it extends an established enforcement line against the Saab network. 1 evidence refs Board ### Venezuela remains on the FATF increased-monitoring list, with no October 2026 plenary update located. The jurisdiction's grey-list status, confirmed at the 19 June 2026 Plenary, should be treated as a standing exposure factor pending the next confirmed plenary outcome. 1 evidence refs Risk ### A managed, named and time-bound pattern of sanctions relief sits alongside continued FATF grey-list status and ongoing Saab-network prosecution activity. The net directional risk posture for Venezuela is not evidenced to have moved this cycle; the Rodriguez delisting and GL60A extension are narrow and do not signal a broader sanctions-relief trajectory against the still-large underlying SDN list. 3 evidence refs Audit ### The Pulido arrest detail rests on press-reported quotation rather than an independently retrieved DOJ release. The documented evidence trail for the conflict-finance finding is currently a secondary-source quote; audit should note the capped probable-tier confidence pending primary-source retrieval. 1 evidence refs Scenario sketches ### AMLA direct-supervision transition and cross-border obliged-entity evasion routing Illustrative scenario for analytical orientation only: as the Anti-Money Laundering Authority established under the AMLA Regulation (Reg (EU) 2024/1620) moves toward direct supervision of designated cross-border obliged entities, alongside the directly applicable AML Regulation (Reg (EU) 2024/1624) and per-state transposition of the sixth AML Directive, a hybrid EU-level and national supervisory perimeter could reshape where evasion-pattern obliged entities choose to establish. This is architecture-over-incident illustration of a structural transition, not an observed development and not a prediction of where any Venezuela-linked flow would route. 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 Venezuela-specific Russia-sanctions-evasion signal found this cycle. T2 · EU AML Package / AMLA no_change Venezuela is outside the EEA/UK and not bound by AMLR/6AMLD/AMLA. T3 · FATF Grey List watch Venezuela remains on the FATF grey list as confirmed at the 19 June 2026 Plenary; next Plenary (28-30 Oct 2026) falls after this window. T4 · Beneficial-Ownership Register Status no_change No public searchable beneficial-ownership register identified for Venezuela. T5 · Crypto & Digital-Asset Integrity watch Binance enabled direct bolívar deposits (15 Oct) to fund stablecoin purchases via a regulated casa de cambio, continuing informal/semi-formal fiat-to-crypto on-ramping outside SUNACRIP's licensed perimeter. T6 · Sanctions Regime Divergence watch US sanctions relief continues to advance unilaterally while EU/UK autonomous listings on Venezuela were not found to have moved, widening the existing divergence. Registers ### Enforcement actions - 31 Dec 2025 - 3 Dec 2025 - 19 Dec 2025 - 1 Dec 2025 - 3 Jan 2026 - 13 Jan 2026 - 2 Oct 2026 - 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 - 10 Jun 2026 - 15 Dec 2025 - 10 Jun 2025 - 14 Apr 2026 - 5 May 2026 - 25 Jul 2025 - 14 Apr 2026 - 14 Apr 2026 - 14 Apr 2026 - 10 Jun 2026 - 13 Feb 2026 - 14 Apr 2026 - 14 Apr 2026 - 25 Jul 2025 - 10 Feb 2026 - 6 Mar 2026 - 28 Sep 2026 - 14 Apr 2026 - 25 Jun 2026 - 28 Sep 2026 - 15 Dec 2025 - 14 Oct 2026 - 16 Oct 2026 - 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) - Venezuela electricity-sector regulatory overhaul - PNAP 2024-2026 biannual review / next FATF plenary review of Venezuela's action plan - PNAP 2024-2026 mid-cycle review amid regime discontinuity - OFAC GL 60 earthquake-relief licence expiry/renewal decision - FATF October 2026 plenary review of VE grey-list status - FATF October 2026 Plenary (UK Presidency) to review grey-list progress - OFAC Venezuela General License 60A renewal/lapse point - - 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 - [Country Policy and Information Note Colombia: Armed groups and criminal gangs](https://assets.publishing.service.gov.uk/media/69b2c874c8010d37b34e0097/COL_CPIN_Armed_groups_and_criminal_gangs.pdf) - [Wikipedia](https://en.wikipedia.org/wiki/Cartel_of_the_Suns) - [US Treasury OFAC](https://ofac.treasury.gov/sanctions-programs-and-country-information/venezuela-related-sanctions) - [US Treasury OFAC (31 CFR Part 591 GL 57 text)](https://ofac.treasury.gov/media/935516/download?inline=) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [US Treasury](https://home.treasury.gov/news/press-releases/sb0207) - [Axios](https://www.axios.com/2026/04/14/venezuela-bank-sanctions-protests-delcy-rodriguez) - [MercoPress](https://en.mercopress.com/2026/04/15/us-lifts-sanctions-on-venezuela-s-central-bank-and-backs-its-return-to-the-imf) - [Bloomberg](https://www.bloomberg.com/news/articles/2026-05-13/venezuela-government-announces-debt-restructuring-process) - [Crowdfund Insider (citing TRM Labs)](https://www.crowdfundinsider.com/2025/12/256449-venezuelas-crypto-ecosystem-continues-to-evolve-amid-global-tension-analysis/) - [Lightspark](https://www.lightspark.com/knowledge/is-crypto-legal-in-venezuela) - [Amnesty International](https://www.amnesty.org/en/latest/news/2026/04/cambodia-casinos-get-state-approval-despite-links-to-human-rights-abuse-at-scamming-compounds/) - [Casino Guardian](https://www.casinoguardian.co.uk/2026/01/27/cambodia-intensifies-crackdown-on-illegal-online-gambling-amid-fatf-scrutiny/) - [NPR](https://www.npr.org/2026/06/21/g-s1-128624/freed-from-cambodias-scam-compounds-trafficking-victims-face-a-new-crisis) - [US Department of State](https://www.state.gov/releases/office-of-the-spokesperson/2025/09/presidential-determination-on-major-drug-transit-or-major-illicit-drug-producing-countries-for-fiscal-year-2026) - [Washington Trade & Tariff Letter](https://www.wttlonline.com/stories/colombia-designated-major-trafficker-in-fraa-review,14278) - [Sanctions Lawyers](https://sanctionslawyers.net/blog-en/the-fatf-grey-list-and-blacklist-complete-guide/) - [https://ofac.treasury.gov/recent-actions/20260213](https://ofac.treasury.gov/recent-actions/20260213) - [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [https://www.kslaw.com/news-and-insights/venezuela-reforms-hydrocarbons-law-a-potential-sea-change-for-foreign-investment-in-the-oil-sector](https://www.kslaw.com/news-and-insights/venezuela-reforms-hydrocarbons-law-a-potential-sea-change-for-foreign-investment-in-the-oil-sector) - [https://sanctionsnews.bakermckenzie.com/ofac-updates-venezuela-general-licenses-and-issues-new-venezuela-faqs/](https://sanctionsnews.bakermckenzie.com/ofac-updates-venezuela-general-licenses-and-issues-new-venezuela-faqs/) - [https://transnetinc.com/venezuela-state-licensed-crypto-mining-requirements-rules-risks-reality](https://transnetinc.com/venezuela-state-licensed-crypto-mining-requirements-rules-risks-reality) - [https://2009-2017.state.gov/j/inl/rls/nrcrpt/2016/vol2/253440.htm](https://2009-2017.state.gov/j/inl/rls/nrcrpt/2016/vol2/253440.htm) - [https://en.wikipedia.org/wiki/2026_in_Colombia](https://en.wikipedia.org/wiki/2026_in_Colombia) - [https://ofac.treasury.gov/recent-actions/20260414_33](https://ofac.treasury.gov/recent-actions/20260414_33) - [https://ofac.treasury.gov/media/935516/download?inline=](https://ofac.treasury.gov/media/935516/download?inline=) - [https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/CFATF-FUR-Venezuela-2025.pdf.coredownload.inline.pdf](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/CFATF-FUR-Venezuela-2025.pdf.coredownload.inline.pdf) - [https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/CFATF-Mutual-Evaluation-Venezuela.pdf.coredownload.inline.pdf](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/CFATF-Mutual-Evaluation-Venezuela.pdf.coredownload.inline.pdf) - [https://www.ccn.com/news/crypto/tether-usdt-182m-venezuela-crypto-crackdown/](https://www.ccn.com/news/crypto/tether-usdt-182m-venezuela-crypto-crackdown/) - [https://coingeek.com/did-tether-freeze-venezuela-stablecoins-is-iran-next/](https://coingeek.com/did-tether-freeze-venezuela-stablecoins-is-iran-next/) - [https://www.k2integrity.com/en/knowledge/policy-alerts/venezuela-update-political-transition-and-sanctions-and-aml-risk-overview/](https://www.k2integrity.com/en/knowledge/policy-alerts/venezuela-update-political-transition-and-sanctions-and-aml-risk-overview/) - [https://sanctionsnews.bakermckenzie.com/ofac-issues-new-venezuela-related-general-licenses-authorizing-commercial-negotiations-of-contingent-contracts-with-gov-and-financial-services-involving-named-venezuelan-banks/](https://sanctionsnews.bakermckenzie.com/ofac-issues-new-venezuela-related-general-licenses-authorizing-commercial-negotiations-of-contingent-contracts-with-gov-and-financial-services-involving-named-venezuelan-banks/) - [https://home.treasury.gov/news/press-releases/sb0207](https://home.treasury.gov/news/press-releases/sb0207) - [https://www.federalregister.gov/documents/2026/09/11/2026-18569/publication-of-venezuela-sanctions-regulations-web-general-licenses-30b-and-51](https://www.federalregister.gov/documents/2026/09/11/2026-18569/publication-of-venezuela-sanctions-regulations-web-general-licenses-30b-and-51) - [https://bex.co/blog/2026/03/13/venezuela-usdt-shadow-economy-tether-failed-state-de-facto-dollar](https://bex.co/blog/2026/03/13/venezuela-usdt-shadow-economy-tether-failed-state-de-facto-dollar) - [https://commonslibrary.parliament.uk/research-briefings/cbp-10452/](https://commonslibrary.parliament.uk/research-briefings/cbp-10452/) - [https://www.fddaction.org/policy-alerts/2026/01/09/policy-alert-maduro-capture-venezuela-transition/](https://www.fddaction.org/policy-alerts/2026/01/09/policy-alert-maduro-capture-venezuela-transition/) - [https://www.fatf-gafi.org/en/countries/detail/Venezuela.html](https://www.fatf-gafi.org/en/countries/detail/Venezuela.html) - [https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/](https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/) - [https://ofac.treasury.gov/recent-actions/20260318](https://ofac.treasury.gov/recent-actions/20260318) - [https://www.leechtishman.com/insights/blog/venezuela-new-ofac-general-licenses-gl-56-and-gl-57/](https://www.leechtishman.com/insights/blog/venezuela-new-ofac-general-licenses-gl-56-and-gl-57/) - [https://www.npr.org/2026/04/02/g-s1-116142/u-s-lift-sanctions-venezuela-president-delcy-rodriguez](https://www.npr.org/2026/04/02/g-s1-116142/u-s-lift-sanctions-venezuela-president-delcy-rodriguez) - [https://www.crowdfundinsider.com/2025/12/256449-venezuelas-crypto-ecosystem-continues-to-evolve-amid-global-tension-analysis/](https://www.crowdfundinsider.com/2025/12/256449-venezuelas-crypto-ecosystem-continues-to-evolve-amid-global-tension-analysis/) - [https://ofac.treasury.gov/sanctions-programs-and-country-information](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [https://ofac.treasury.gov/faqs/topic/1581](https://ofac.treasury.gov/faqs/topic/1581) - [https://www.federalregister.gov/documents/2026/09/23/2026-19422/publication-of-venezuela-sanctions-regulations-web-general-licenses-5x-and-5y](https://www.federalregister.gov/documents/2026/09/23/2026-19422/publication-of-venezuela-sanctions-regulations-web-general-licenses-5x-and-5y) - [https://www.cnn.com/2026/10/02/politics/david-rivera-rubio-congressman-venezuela-lobbying](https://www.cnn.com/2026/10/02/politics/david-rivera-rubio-congressman-venezuela-lobbying) - [https://plisio.net/tax/crypto-taxation-in-venezuela](https://plisio.net/tax/crypto-taxation-in-venezuela) - [https://ofac.treasury.gov/media/936396/download?inline=](https://ofac.treasury.gov/media/936396/download?inline=) - [https://ofac.treasury.gov/recent-actions/20260928](https://ofac.treasury.gov/recent-actions/20260928) - [https://www.consilium.europa.eu/en/policies/venezuela/timeline-venezuela/](https://www.consilium.europa.eu/en/policies/venezuela/timeline-venezuela/) - [https://www.cuentasclarasdigital.org/2026/09/abogados-bajo-la-lupa-venezuela-amplia-controles-antilavado-y-abre-debate-sobre-el-secreto-profesional/](https://www.cuentasclarasdigital.org/2026/09/abogados-bajo-la-lupa-venezuela-amplia-controles-antilavado-y-abre-debate-sobre-el-secreto-profesional/) - [https://tuabogado.net/alerta-para-abogados-y-empresas-inmobiliarias-venezuela-intensificara-en-2026-la-supervision-contra-la-legitimacion-de-capitales/](https://tuabogado.net/alerta-para-abogados-y-empresas-inmobiliarias-venezuela-intensificara-en-2026-la-supervision-contra-la-legitimacion-de-capitales/) - [https://vlexvenezuela.com/vid/providencia-mediante-establecen-normas-764501161](https://vlexvenezuela.com/vid/providencia-mediante-establecen-normas-764501161) - [https://www.criptonoticias.com/mercados/crixto-renovacion-operaciones-2026-venezuela/](https://www.criptonoticias.com/mercados/crixto-renovacion-operaciones-2026-venezuela/) - [https://morocotacoin.news/economia-digital/sunacrip-pdvsa-cripto/](https://morocotacoin.news/economia-digital/sunacrip-pdvsa-cripto/) - [https://ofac.treasury.gov/recent-actions/20261016](https://ofac.treasury.gov/recent-actions/20261016) - [https://www.riotimesonline.com/us-delists-venezuelas-jorge-rodriguez-ofac/](https://www.riotimesonline.com/us-delists-venezuelas-jorge-rodriguez-ofac/) - [https://www.govinfo.gov/content/pkg/FR-2026-10-13/html/2026-20831.htm](https://www.govinfo.gov/content/pkg/FR-2026-10-13/html/2026-20831.htm) - [https://www.infobae.com/colombia/2026/10/11/estados-unidos-confirma-la-captura-de-alvaro-pulido-empresario-colombiano-socio-de-alex-saab-por-lavado-de-dinero/](https://www.infobae.com/colombia/2026/10/11/estados-unidos-confirma-la-captura-de-alvaro-pulido-empresario-colombiano-socio-de-alex-saab-por-lavado-de-dinero/) - [https://www.sudeaseg.gob.ve/Descargas/Admintraci%C3%B3n%20de%20Riesgo%20LC-FT-FPADM/Evaluaciones%20Mutuas%20GAFIC.pdf](https://www.sudeaseg.gob.ve/Descargas/Admintraci%C3%B3n%20de%20Riesgo%20LC-FT-FPADM/Evaluaciones%20Mutuas%20GAFIC.pdf) - [U.S. Treasury OFAC](https://ofac.treasury.gov/recent-actions/sanctions-list-updates) - [Mondaq](https://www.mondaq.com/unitedstates/government-public-sector/1858552/sanctions-update-october-19-2026) - [Citadel365](https://citadel365.com/blogs/fatf-june-2026-update-grey-list-and-black-list-changes/) - [FATF](https://www.fatf-gafi.org/en/news/fatf-week-october-2026.html) - [Unidad Nacional de Inteligencia Financiera (UNIF), Venezuela](https://www.unif.gob.ve/marco-legal/) - [Cuentas Claras Digital](https://www.cuentasclarasdigital.org/2026/09/abogados-bajo-la-lupa-venezuela-amplia-controles-antilavado-y-abre-debate-sobre-el-secreto-profesional/) - [El Diario (Venezuela)](https://eldiario.com/2026/08/16/comisiones-bancarias-bcv/) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Venezuela](https://www.fatf-gafi.org/en/countries/detail/Venezuela.html) - [Jurisdictions under Increased Monitoring - 13 June 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2025.html) - [Jurisdictions under Increased Monitoring - 24 October 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html) - [Jurisdictions under Increased Monitoring - 21 February 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2025.html) - [Mutual Evaluation of Venezuela](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofvenezuela.html) - [Countries / Jurisdictions](https://www.fatf-gafi.org/en/countries.html) - [Jurisdictions under Increased Monitoring - June 2024](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2024.html) - [Venezuela-Related Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/venezuela-related-sanctions) - [Venezuela Sanctions](https://ofac.treasury.gov/faqs/topic/1581) - [Venezuela-related Designation Removal | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260401) - [Venezuela Sanctions Regulations 31 CFR part 591 ...](https://ofac.treasury.gov/media/934886/download?inline=) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [595. What does Venezuela-related General License 5W ...](https://ofac.treasury.gov/faqs/595) - [OFFICE OF FOREIGN ASSETS CONTROL Venezuela ...](https://ofac.treasury.gov/media/934026/download?inline=) - [Frequently Asked Questions - Newly Added | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/added) - [672. Can I export or reexport diluents to Venezuela?](https://ofac.treasury.gov/faqs/672) - [Issuance of New and Amended Venezuela-related General Licenses | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260327_33) - [Counter Terrorism Designations; Transnational Criminal Organizations Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251203) - [Counter Terrorism Designations and Designation Update; Transnational Criminal Organizations Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250717) - [Counter Terrorism and Transnational Criminal Organizations Designation | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250624) - [OFAC ALERT International Cartels Designated as Foreign Terrorist](https://ofac.treasury.gov/media/934096/download?inline=) - [Publication of Venezuela-related Frequently Asked Question | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260331_66) - [Issuance of Venezuela-related General Licenses | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260213) - [Venezuela-related Designations; Issuance of Venezuela-related General License; Publication of Amended Venezuela-related Frequently Asked Question | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251219) - [Issuance of Venezuela-related General License and Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260318) - [Venezuela: Council renews restrictive measures and lists a further 15 individuals in view of the situation in the country - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/01/10/venezuela-council-renews-restrictive-measures-and-lists-a-further-15-individuals-in-view-of-the-situation-in-the-country/) - [Venezuela: Council renews restrictive measures by one year - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/12/15/venezuela-council-renews-restrictive-measures-by-one-year/) - [Timeline - Venezuela - consilium.europa.eu](https://www.consilium.europa.eu/en/policies/venezuela/timeline-venezuela/) - [Venezuela: Council reviews restrictive measures - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2023/11/13/venezuela-council-reviews-restrictive-measures/) - [Venezuela - consilium.europa.eu](https://www.consilium.europa.eu/en/policies/venezuela/) - [Sanctions - consilium.europa.eu - European Union](https://www.consilium.europa.eu/en/topics/sanctions/) - [Types of sanctions the EU adopts - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-different-types/) - [UN Meetings Coverage and Press Releases | We’ve got the United Nations covered](https://press.un.org/en) - [Overview of sanctions and related resources - Finance - European Commission](https://finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures/overview-sanctions-and-related-resources_en) - [| UN Meetings Coverage and Press Releases](https://press.un.org/en/content/security-council) - [Maduro’s “Illicit” Gold Targeted by US Sanctions | OCCRP](https://www.occrp.org/en/news/maduros-illicit-gold-targeted-by-us-sanctions) - [Blood Gold and New Opportunities: Foreign Firms Are Poised to Reenter Venezuela's Wild South | OCCRP](https://www.occrp.org/en/feature/blood-gold-and-new-opportunities-foreign-firms-are-poised-to-reenter-venezuelas-wild-south) - [Venezuela: Oil, mining and the risks of foreign investment | Global Witness](https://globalwitness.org/en/campaigns/fossil-fuels/ecocide-in-venezuela-oil-mining-and-the-risks-of-foreign-investment/) - [How Venezuelan Gold is Trafficked Through Brazil’s Borderlands to the US | OCCRP](https://www.occrp.org/en/feature/how-venezuelan-gold-is-trafficked-through-brazils-borderlands-to-the-us) - [Venezuela-related Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251231) - [President Maduro Linked to Ugandan Gold Probe | OCCRP](https://occrp.org/en/27-ccwatch/cc-watch-briefs/9381-maduro-linked-to-ugandan-gold-probe) - [Five Questions on the Gold Trade | OCCRP](https://www.occrp.org/en/feature/five-questions-on-the-gold-trade) - [Organized Crime and Corruption Reporting Project | OCCRP](https://www.occrp.org/en) - [Undermining sanctions | Global Witness](https://globalwitness.org/en/campaigns/corruption-and-money-laundering/undermining-sanctions/) - [Venezuela sanctions: 3 steps for crypto compliance teams](https://www.elliptic.co/blog/venezuela-sanctions-steps-for-crypto-compliance-teams) - [Counter Narcotics Designation; Issuance of Venezuela-related General License | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250304) - [The Maduro Superseding Indictment and Cryptocurrency in Venezuela’s Sanctions-pressured Economy | TRM Blog](https://www.trmlabs.com/resources/blog/the-maduro-superseding-indictment-and-cryptocurrency-in-venezuelas-sanctions-pressured-economy) - [Archive of Selected Revoked and Expired General Licenses | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/venezuela-related-sanctions/archive-of-selected-revoked-and-expired-general-licenses) - [Frequently Asked Questions Related to the Suspension of ...](https://ofac.treasury.gov/media/932821/download?inline=) - [Federal Register/Vol. 90, No. 139/Wednesday, July 23, ...](https://ofac.treasury.gov/media/934511/download?inline=) - [Delcy Rodriguez, Maduro Leadership Team Assert Control After US Capture - Bloomberg](https://www.bloomberg.com/news/articles/2026-01-03/delcy-rodriguez-maduro-leadership-team-assert-control-after-capture) - [Delcy Rodríguez Sworn in as Acting Venezuela President - Bloomberg](https://www.bloomberg.com/news/articles/2026-01-05/maduro-s-son-backs-rodriguez-even-as-she-extends-hand-to-trump) - [Raid Months in the Making Captured Venezuela’s Maduro in Just Hours, US Says](https://www.bloomberg.com/news/articles/2026-01-03/strike-against-venezuela-how-us-took-maduro) - [Maduro Captured, Indicted After US Airstrikes on Venezuela - Bloomberg](https://www.bloomberg.com/news/articles/2026-01-03/trump-says-venezuela-s-maduro-captured-and-flown-out-of-country-mjy3kziv) - [Venezuela’s Rodriguez Asks US to Cooperate After Maduro Raid - Bloomberg](https://www.bloomberg.com/news/articles/2026-01-05/venezuela-s-rodriguez-asks-us-for-cooperation-after-maduro-raid) - [Watch Inside the Nighttime Raid to Capture Venezuela's Maduro - Bloomberg](https://www.bloomberg.com/news/videos/2026-01-08/how-the-us-turned-off-the-lights-during-maduro-s-capture-video) - [Venezuela’s repressive State apparatus ‘intact’ despite leadership change | UN News](https://news.un.org/en/story/2026/03/1167126) - [Maduro Capture in Venezuela: Did the US Operation Violate International Law? - Bloomberg](https://www.bloomberg.com/news/articles/2026-01-06/maduro-capture-in-venezuela-did-the-us-operation-violate-international-law) - [US Strikes Venezuela: Live Updates as Maduro Captured, Indicted - Bloomberg](https://www.bloomberg.com/news/live-blog/2026-01-03/explosions-in-venezuela) - [Watch US Strikes Venezuela, Maduro Captured and Indicted - Bloomberg](https://www.bloomberg.com/news/videos/2026-01-03/us-strikes-venezuela-captures-maduro-video) - [FinCEN Warns Financial Institutions to Guard Against Corrupt Venezuelan Money Flowing to U.S. | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-warns-financial-institutions-guard-against-corrupt-venezuelan-money) - [Updated FinCEN Advisory Warns Against Continued Corrupt Venezuelan Attempts to Steal, Hide, or Launder Money | FinCEN.gov](https://www.fincen.gov/news/news-releases/updated-fincen-advisory-warns-against-continued-corrupt-venezuelan-attempts) - [Updated Advisory on Widespread Public Corruption in ...](https://www.fincen.gov/sites/default/files/advisory/2019-05-03/Venezuela%20Advisory%20FINAL%20508.pdf) - [Advisories | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets/advisories?field_date_release_value=&field_date_release_value_1=&field_tags_advisory_target_id=All&page=1) - [1 FIN-2019-A002 May 3, 2019 Updated Advisory on Widespread Public Corruption](https://www.fincen.gov/system/files/advisory/2019-05-03/Venezuela%20Advisory%20FINAL%20508.pdf) - [1245 | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/1245) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html) - [Commission adds Russia to list of high-risk jurisdictions to strengthen international fight against financial crime](https://ec.europa.eu/commission/presscorner/detail/en/ip_25_2910) - [Protecting the EU’s financial system - Finance - European Commission](https://finance.ec.europa.eu/news/protecting-eus-financial-system-2025-07-16_en) - [The UK Sanctions List - GOV.UK](https://www.gov.uk/government/publications/the-uk-sanctions-list) - [OFSI Consolidated List Search](https://sanctionssearchapp.ofsi.hmtreasury.gov.uk/) - [[Withdrawn] Financial sanctions targets by regime - GOV.UK](https://www.gov.uk/government/collections/financial-sanctions-regime-specific-consolidated-lists-and-releases) - [UK sanctions - GOV.UK](https://www.gov.uk/government/collections/uk-sanctions) - [Venezuela: list of designations and sanctions notices - GOV.UK](https://www.gov.uk/guidance/venezuela-list-of-designations-and-sanctions-notices) - [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [Money Laundering Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2) - [FCDO - UK Sanctions List Search - GOV.UK](https://search-uk-sanctions-list.service.gov.uk/) - [Elliott Affiliate Amber Energy Makes Last-Minute $8.82 Billion Bid for Citgo - Bloomberg](https://www.bloomberg.com/news/articles/2025-08-13/citgo-auction-latest-elliott-affiliate-makes-8-82-billion-bid) - [Citgo Auction: Elliott Tops Gold Reserve (GRZ CN) Bid, Court Adviser Says - Bloomberg](https://www.bloomberg.com/news/articles/2025-08-26/citgo-auction-elliott-tops-gold-reserve-grz-cn-bid-court-adviser-says) - [Elliott Affiliate’s $6 Billion Citgo-Shares Bid Wins Auction - Bloomberg](https://www.bloomberg.com/news/articles/2025-11-25/elliott-affiliate-s-bid-to-buy-citgo-approved-by-delaware-judge) - [Elliott Affiliate Amber Energy Weighs New Bid for Citgo as Legal Risks Ease - Bloomberg](https://www.bloomberg.com/news/articles/2025-06-16/elliott-affiliate-weighs-new-bid-for-citgo-as-legal-risks-ease) - [Elliott Affiliate Amber Energy Wins Citgo Auction With $7.28 Billion Bid - Bloomberg](https://www.bloomberg.com/news/articles/2024-09-27/elliott-affiliate-wins-citgo-auction-with-7-28-billion-bid) - [US Judge Rules PDVSA Bonds Valid, Clearing Way for Citgo Sale - Bloomberg](https://www.bloomberg.com/news/articles/2025-09-18/us-judge-rules-pdvsa-bonds-valid-clearing-way-for-citgo-sale) - [Elliott Floats New $5.3 Billion Citgo Bid as Deal Faces Backlash - Bloomberg](https://www.bloomberg.com/news/articles/2024-11-07/elliott-floats-new-5-3-billion-citgo-bid-as-deal-faces-backlash) - [Venezuela, Bidders Clash Over Citgo’s Value in Court Auction - Bloomberg](https://www.bloomberg.com/news/articles/2025-09-15/venezuela-bidders-clash-over-citgo-s-value-in-court-auction) - [Judge Clears Way for Final Bids on Citgo in Setback to PDVSA - Bloomberg](https://www.bloomberg.com/news/articles/2024-05-17/judge-clears-way-for-final-bids-on-citgo-in-setback-to-pdvsa) - [Citgo Auction Adviser Is Said to Recommend Gold Reserve Bid - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-01/citgo-auction-adviser-is-said-to-recommend-gold-reserve-bid) - [Venezuela’s Dark Fleet of Oil Tankers Emerges After Maduro’s Capture by US - Bloomberg](https://www.bloomberg.com/news/articles/2026-01-14/venezuela-s-dark-fleet-of-oil-tankers-emerges-after-maduro-s-capture-by-us) - [Venezuela’s Dark Fleet Tankers Stuck as Oil Industry Shifts Post-Maduro - Bloomberg](https://www.bloomberg.com/news/articles/2026-04-06/trio-of-ghost-ships-left-in-venezuela-limbo-after-maduro-s-exit) - [US Sanctions Oil Tankers, Companies Linked to Venezuela’s Maduro Regime - Bloomberg](https://www.bloomberg.com/news/articles/2025-12-31/us-sanctions-oil-tankers-companies-with-links-to-venezuela) - [US Forces Capture Another Tanker Linked to Venezuela’s Sanctioned Oil Trade - Bloomberg](https://www.bloomberg.com/news/articles/2026-01-15/us-seizes-sixth-oil-tanker-in-waters-around-venezuela) - [Updated Price Cap Coalition Advisory for the Maritime Oil ...](https://ofac.treasury.gov/media/933506/download?inline=) - [US Boards Sanctioned Venezuela-Linked Oil Tanker in Indian Ocean - Bloomberg](https://www.bloomberg.com/news/articles/2026-02-09/us-boards-sanctioned-venezuela-linked-oil-tanker-in-indian-ocean) - [SANCTIONS ADVISORY - Guidance for Shipping and ...](https://ofac.treasury.gov/media/934236/download?inline=) - [Venezuela Sees Ghost Tankers Offload Oil After US Intervention, Data Show - Bloomberg](https://www.bloomberg.com/news/articles/2026-05-14/ghost-oil-tankers-reversal-signals-venezuela-s-long-road-ahead) - [Russia's war of aggression against Ukraine: Council sanctions 9 shadow fleet enablers - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/12/15/russia-s-war-of-aggression-against-ukraine-council-sanctions-9-shadow-fleet-enablers/) - [The Bolivarian Republic of Venezuela](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/CFATF-FUR-Venezuela-2025.pdf.coredownload.inline.pdf) - [Follow-up Reports to the Mutual Evaluation of Venezuela](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Follow-upreportstothemutualevaluationofvenezuela.html) - [Bolivarian Republic of Venezuela, Mutual Evaluation Report](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/CFATF-Mutual-Evaluation-Venezuela.pdf.coredownload.inline.pdf) - [Mutual Evaluations](https://www.fatf-gafi.org/en/publications/Mutualevaluations.html) - [3rd Enhanced Follow-up report of Venezuela](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Venezuela-Follow-Up-Report-2025.html) - [West Bank-related Designations; Transnational Criminal Organizations Designation | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20240711) - [US Designates Six Latin American Drug Cartels as Terror Groups | OCCRP](https://www.occrp.org/en/news/us-designates-six-latin-american-drug-cartels-as-terror-groups) - [FinCEN Alert, FIN-2025-Alert003, November 26, 2025](https://www.fincen.gov/system/files/FinCEN_Alert_Cross_Border_FINAL508.pdf) - [Country policy and information note: armed groups and criminal gangs, Colombia, March 2026 (accessible) - GOV.UK](https://www.gov.uk/government/publications/colombia-country-policy-and-information-notes/country-policy-and-information-note-armed-groups-and-criminal-gangs-colombia-march-2026-accessible) - [The Rapid Rise of Venezuela's 'Tren de Aragua' Gang ...](https://www.occrp.org/en/project/narcofiles-the-new-criminal-order/the-rapid-rise-of-venezuelas-tren-de-aragua-gang-leaves-destruction-and-death-in-its-wake) - [United States of America](https://www.un.org/counterterrorism/sites/default/files/2026-03/united_states_of_america_-_contribution_to_sg_report_on_activities_of_the_united_nations_system_in_implementing_the_united_nations_global_counter-terrorism_strategy_2025.pdf) - [Country Policy and Information Note Colombia: Armed groups and criminal gangs](https://assets.publishing.service.gov.uk/media/69b2c874c8010d37b34e0097/COL_CPIN_Armed_groups_and_criminal_gangs.pdf) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [US Department of the Treasury / OFAC](https://ofac.treasury.gov/sanctions-programs-and-country-information/venezuela-related-sanctions) - [Council of the European Union](https://www.consilium.europa.eu/en/policies/venezuela/timeline-venezuela/) - [CFATF / FATF Global Network](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/CFATF-FUR-Venezuela-2025.pdf.coredownload.inline.pdf) - [OCCRP](https://www.occrp.org/en/feature/blood-gold-and-new-opportunities-foreign-firms-are-poised-to-reenter-venezuelas-wild-south) - [Global Witness](https://globalwitness.org/en/campaigns/fossil-fuels/ecocide-in-venezuela-oil-mining-and-the-risks-of-foreign-investment/) - [Bloomberg](https://www.bloomberg.com/news/articles/2026-01-03/trump-says-venezuela-s-maduro-captured-and-flown-out-of-country-mjy3kziv) - [European Commission](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [HM Treasury](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [FinCEN](https://www.fincen.gov/system/files/FinCEN_Alert_Cross_Border_FINAL508.pdf) Coverage gaps fim-int-2026-07-07-G001: Independent primary-source confirma… fim-int-2026-07-07-G001: Independent primary-source confirmation is needed to fully close out whether any OFAC action concerning Delcy Rodriguez occurred around 1 April 2026, given the challenge-review hard-flag finding that the baseline's claimed delisting is unsubstantiated. [resolved] fim-int-2026-07-07-G002: A dated, direct OFAC page cross-che… fim-int-2026-07-07-G002: A dated, direct OFAC page cross-check confirming no further Panama-shell designations occurred between the corrected 19 December 2025 action and 1 April 2026 would close the residual date-conflation risk flagged in challenge finding f-002. [resolved] fim-int-2026-07-07-G003: Direct citation of the current HM T… fim-int-2026-07-07-G003: Direct citation of the current HM Treasury Money Laundering Advisory Notice text (rather than inference) would upgrade the UK HRTC status claim for Venezuela from Possible to a higher confidence tier. [resolved] fim-int-2026-07-07-G004: The ratified typology library (sent… fim-int-2026-07-07-G004: The ratified typology library (sentinel-typology-library-v1.0.json) was not available in this cycle's evidence bundle, preventing typology_observations matching against fim-typ-001..020. [resolved] fim-int-2026-07-07-G005: No RegTech/AI transaction-monitorin… fim-int-2026-07-07-G005: No RegTech/AI transaction-monitoring or perpetual-KYC regulatory guidance for Venezuela's banking or virtual-asset sectors was located; a SUDEBAN or UNIF technology-supervision circular, if it exists, would close this D6 gap. [resolved] fim-int-2026-07-07-G006: Updated commodity-flow/vessel-track… fim-int-2026-07-07-G006: Updated commodity-flow/vessel-tracking data (e.g., Kpler or Windward AIS records) for the period since February 2026 would allow a firmer determination of whether the dark-fleet evasion architecture is disrupted, evolving, or reconstituting, correcting the challenge-flagged overstatement of 'disrupted' status. [resolved] fim-int-2026-07-14-G001: No direct primary confirmation of S… fim-int-2026-07-14-G001: No direct primary confirmation of SUNACRIP's current licensing/enforcement status was located beyond secondary TRM Labs synthesis. [resolved] fim-int-2026-07-14-G002: No direct SDNY indictment filing wa… fim-int-2026-07-14-G002: No direct SDNY indictment filing was reviewed to confirm the 'patronage system' reframing of Cartel de los Soles. [resolved] fim-int-2026-07-14-G003: No VE-specific beneficial-ownership… fim-int-2026-07-14-G003: No VE-specific beneficial-ownership register development or D6 compliance-technology development was located this cycle. [resolved] fim-int-2026-07-14-G004: No IMF primary debt-sustainability-… fim-int-2026-07-14-G004: No IMF primary debt-sustainability-analysis document was located for the Venezuela restructuring. [resolved] fim-int-2026-08-05-G001: No T1/T2 primary Gaceta Oficial tex… fim-int-2026-08-05-G001: No T1/T2 primary Gaceta Oficial text for the Organic Hydrocarbons Law Reform was retrieved this cycle; confidence capped at Assessed. [resolved] fim-int-2026-08-05-G002: No VE-specific PEP-classification f… fim-int-2026-08-05-G002: No VE-specific PEP-classification finding (FCA thematic review / FATF PEP guidance) was located this cycle. [resolved] fim-int-2026-08-05-G003: No second distinct TBML corridor (e… fim-int-2026-08-05-G003: No second distinct TBML corridor (e.g. UAE over/under-invoicing) touching Venezuela was located this cycle. [resolved] fim-int-2026-08-05-G004: No Venezuela-specific RegTech/AI-tr… fim-int-2026-08-05-G004: No Venezuela-specific RegTech/AI-transaction-monitoring development was identified this cycle; D6 remains a standing watch item. [resolved] fim-int-2026-08-05-G005: Cambodia (KH) Tier-D check yielded … fim-int-2026-08-05-G005: Cambodia (KH) Tier-D check yielded no material findings this cycle and is logged as a gap rather than an invented finding. [resolved] fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): Tier D jurisdictions (KH, LA, MX, CO) and D3/D4 domains were not actively searched this cycle given the pooled union budget's VE-bound scope. [resolved] fim-int-2026-08-21-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-08-21-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): No cross-bloc (EU/UK) VE-sanctions-posture comparison data was reached this cycle, so T6 sanctions-regime-divergence cannot yet be fully characterised. [resolved] fim-int-2026-08-21-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-08-21-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): Tether's VE-linkage for the $182M freeze is press/blockchain-analytics sourced only; no T1/T2 confirmation from Tether itself. [resolved] fim-int-2026-09-14-G001: Tier D watch jurisdictions (KH/LA/M… fim-int-2026-09-14-G001: Tier D watch jurisdictions (KH/LA/MX/CO) were not actively searched this pass, which was bound to VE. [resolved] fim-int-2026-09-14-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-14-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): No T1 confirmation of the $182m Tether freeze figure or wallet ownership; all corroborating sources are Tier 3/4 crypto press. [resolved] fim-int-2026-09-14-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-14-G003 ({'scheme': 'financial_integrity', 'value': 'D3'}): No material new D3 enabler-jurisdiction finding surfaced this cycle; domestic institutional capture dominates over an external enabler dynamic. [resolved] fim-int-2026-09-14-G004: No enforcement_actions[] evidenced … fim-int-2026-09-14-G004: No enforcement_actions[] evidenced this cycle for Venezuela specifically beyond the OFAC designation and sanctions-changes items already captured. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): D2-D6 domains and Tier D jurisdictions received only cursory review this cycle; budget was concentrated on the VE political-transition/sanctions story. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): GL 56/57 primary OFAC text was not directly retrieved this cycle; corroboration rests on T3 law-firm commentary. [resolved] fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', 'value': 'D2'}): No T1 anchor confirming current VE beneficial-ownership framework status; jurisdiction structurally thin-record for corporate-transparency publications. [resolved] fim-int-2026-10-04-G001: No VE-specific Tier D (KH, LA, MX, … fim-int-2026-10-04-G001: No VE-specific Tier D (KH, LA, MX, CO) corridor signal was independently queried this cycle because searches were JID-bound to Venezuela; this is recorded as a coverage gap rather than a no-material-change finding for those jurisdictions. [resolved] fim-int-2026-10-04-G002: No subsequent FATF/CFATF plenary ou… fim-int-2026-10-04-G002: No subsequent FATF/CFATF plenary outcome on Venezuela's action-plan progress was located inside this cycle's window; the most recent located statement is the 19 June 2026 plenary. [resolved] fim-int-2026-10-04-G003: Mining-record-retention period for … fim-int-2026-10-04-G003: Mining-record-retention period for VE crypto obligations and SUNACRIP institutional status (D2/D5 overlap) remain thinly sourced this cycle, relying on a single T4 vendor explainer. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No UNIF primary circular was independently retrieved confirming the reported Q4 2026 sectoral AML supervision plan for lawyers, notaries and real-estate firms. [resolved] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): No SUNACRIP primary source (sunacrip.gob.ve) was reachable this cycle to confirm the practical consequence of SUNACRIP's institutional restructuring for the licensing perimeter. [resolved] fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): No enforcement action against a VE obligated entity was located this cycle. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No October 2026 FATF plenary outcome for Venezuela was located, leaving the grey-list status carried forward from the June 2026 plenary rather than independently confirmed this cycle. [open] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): DOJ's own press release on the Álvaro Pulido Vargas arrest was not independently retrieved this cycle, capping confidence at Probable. [open] fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): ONCDOFT Circular N.3-2026 full primary text was not located; AML registration perimeter for lawyers rests on single T2 legal-commentary source. [open] fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): No public searchable beneficial-ownership register was identified for Venezuela this cycle; D2 standing gap persists. [open] fim-int-2026-10-25-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G003 ({'scheme': 'financial_integrity', 'value': 'D6'}): No RegTech/compliance-technology development was found for Venezuela this cycle. [open] FIM-GAP-001 (D2): Despite CFATF re-ratings on some technical… FIM-GAP-001 (D2): 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. FIM-GAP-002 (D4): Global Witness satellite monitoring found … FIM-GAP-002 (D4): 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. FIM-GAP-003 (D1): The abrupt, US-driven leadership transitio… FIM-GAP-003 (D1): 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. FIM-GAP-004 (D6): No public evidence was found in this resea… FIM-GAP-004 (D6): 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 Venezuela-Related Sanctions program page shows a 'Program Last Updated' stamp of 28 Sep 2026 [[Source 1]](#sec-sources) Probable · 1 source 10 years imprisonment plus forfeiture of Florida real property for covert, undisclosed lobbying (2017-2018) on behalf of Venezuela's PSUV government via a USD 50 million consulting contract tied to then-Foreign Minister Delcy Rodriguez [[Source 1]](#sec-sources) Probable · 1 source Over 50 defendants on trial in Caracas tied to SUNACRIP's 2023 collapse; no successor crypto regulator formally established; estimated embezzlement USD 5.55bn (official) to USD 16.9-23bn (independent) [[Source 1]](#sec-sources) Probable · 1 source Venezuela remains under FATF increased monitoring per the 19 June 2026 plenary statement; deficient, inaccessible beneficial-ownership information flagged as an open action-plan item [[Source 1]](#sec-sources) Probable · 1 source GL 52C (14 Sep 2026) narrows/expands PDVSA-contract signing authority within the Venezuela sanctions program [[Source 1]](#sec-sources) Probable · 1 source Authorises financial-services transactions and correspondent banking with BCV, Banco de Venezuela, Banco Digital de los Trabajadores, Banco del Tesoro [[Source 1]](#sec-sources) Probable · 1 source Authorises earthquake-relief-related transactions and fund transfers via third-country persons through 23 October 2026 [[Source 1]](#sec-sources) Probable · 1 source US OFAC accelerating sanctions relief since January 2026 while EU renewed human-rights sanctions to 10 January 2027 with no matching UK easing found [[Source 1]](#sec-sources) Probable · 1 source Reported Q4 2026 sectoral supervision plan targeting lawyers, notaries, accountants and real-estate firms under LOCDOFT [[Source 1]](#sec-sources) Uncertain · 1 source Under intervenor/restructuring board since March 2023 PDVSA-Cripto scandal; continued issuing renewal licences to Crixto and Kontigo in 2026 [[Source 1]](#sec-sources) Probable · 1 source remains on FATF 'Jurisdictions under Increased Monitoring' (grey) list, confirmed at 19 June 2026 Plenary [[Source 1]](#sec-sources) Probable · 1 source delisted from OFAC SDN list [[Source 1]](#sec-sources) Probable · 1 source OFAC amended General License 60 to 60A on 16 October 2026, extending the earthquake-relief authorisation first issued 25 June 2026 (due to expire 23 October 2026) [[Source 1]](#sec-sources) Probable · 1 source Arrested 11 October 2026 on two federal money-laundering/bribery indictments linked to Maduro-government/PDVSA humanitarian-programme fraud; associate of sanctioned financier Alex Saab [[Source 1]](#sec-sources) Probable · 1 source Crypto regulator remains in restructuring since March 2023 PDVSA-Cripto scandal; National Assembly Innovation Subcommittee holding technical tables toward a new crypto law, no bill filed [[Source 1]](#sec-sources) Probable · 1 source Standing AML/CTF regime rests on LOCDOFT framework with ONCDOFT as coordinating authority; assessed by GAFILAT/GAFIC as institutionally weak [[Source 1]](#sec-sources) Probable · 1 source Jorge Rodríguez, President of Venezuela's National Assembly, removed from the SDN list on 14 October 2026. [[Source 1]](#sec-sources) Probable · 1 source GL 60A issued 16 October 2026, replacing and extending GL 60's earthquake-relief transaction authorisation for Venezuela past the original 23 October 2026 end date. [[Source 1]](#sec-sources) Probable · 1 source Venezuela remains on the FATF grey list ('jurisdictions under increased monitoring') as confirmed at the 19 June 2026 Plenary; no change found this cycle. [[Source 1]](#sec-sources) Probable · 1 source ONCDOFT Circular No. 002-2026 (1 Sept 2026) added certain independent lawyers to Venezuela's Registro Unificado de Sujetos Obligados (RUSO); voided and replaced 7 days later by Circular No. 003-2026, narrowing the scope. [[Source 1]](#sec-sources) Probable · 1 source Remains on FATF's Jurisdictions under Increased Monitoring (grey) list as of 30 Oct 2026 Plenary; deficiencies restated unchanged from June 2026 [[Source 1]](#sec-sources) Probable · 1 source No new designation, delisting, or general-license action dated within 2026-10-25 to 2026-11-01 [[Source 1]](#sec-sources) Probable · 1 source Announced evaluation of non-essential state assets for private-sector transfer/restitution and a stated commitment to judicial-order-based arrests, 29 Oct 2026; no implementing instrument cited [[Source 1]](#sec-sources) Uncertain · 1 source