On a bizarre day for sanctions that saw President Trump
seemingly take action related to North Korea via tweet –
revoke recent measures? scuttle pending ones? – the U.S.
Treasury Department's Office of Foreign Assets Control (OFAC)
added Venezuela's national development bank, Banco de
Desarrollo Economico y Social de Venezuela ("Bandes"), to
OFAC's List of Specially Designated Nationals and Blocked
Persons (the "SDN List"). OFAC "designated"
Bandes pursuant to Executive Order (E.O.) 13850 ("Blocking
Property of Additional Persons Contributing to the Situation in
Venezuela"), the new favorite authority for headline-grabbing
Venezuela sanctions.
The move comes just days after OFAC added Venezuelan state
gold-mining company CVG Compania General de Mineria de Venezuela CA
("Minerven") to the SDN List, and roughly two months
after it did the same to national oil company Petróleos de
Venezuela, S.A. (PDVSA). The Venezuelan gold,
energy, and now financial sectors are
