Which Venezuelan individuals and networks have been sanctioned by OFAC for illicit finance and how were they identified?
Executive summary
OFAC has designated a swath of Venezuelan individuals and networks tied to illicit finance, including members of the Maduro–Flores familial network (notably Efraín “Campos”/Campo Flores and other nephews), intermediary businessmen such as Ramon Carretero Napolitano, oil-sector companies and shadow-fleet tankers, and broader criminal organizations like the Cartel de los Soles for drug‑ and corruption‑related activity [1] [2] [3] [4]. These actions rely on a mix of legal authorities that target narcotics‑related activity, sanctions‑evasion in the oil sector, and persons operating for or on behalf of the Venezuelan government, with OFAC publishing designations and detailed notices in press releases and the Federal Register [5] [6] [7].
1. The familial narco‑corruption network singled out
OFAC has explicitly targeted members of the Maduro–Flores family network, naming individuals tied to Nicolás Maduro and First Lady Cilia Flores’ relatives—such as Carlos Erik Malpica Flores (previously designated and later removed), nephews designated under E.O. 14059, and other familial associates—on grounds of sustaining a narco‑corruption structure that finances regime activity [2] [1] [8]. Treasury framed these designations as cutting off the “narco‑corruption structure” propping up Maduro and described sanctions on specific family associates to disrupt patronage and illicit revenue flows [2] [1].
2. Business intermediaries and facilitators: Carretero, traders, and shipping firms
Beyond blood relatives, OFAC has targeted businessmen who allegedly brokered contracts, shipments, and financial pathways for the regime; Ramon Carretero Napolitano, a Panamanian businessman with contracts and partnerships tied to the Maduro‑Flores circle, is named as facilitating petroleum shipments for the Venezuelan government [1]. Treasury also designated multiple oil‑sector companies and identified specific shipping companies and tankers—naming owners, managers, and individual vessels as blocked property—for operating in Venezuela’s oil trade and enabling sanctions evasion [3] [9].
3. Criminal organizations: Cartel de los Soles and the intersection with transnational trafficking
In a major escalation, OFAC designated Cartel de los Soles as a specially designated global terrorist/criminal organization, accusing it of materially assisting foreign terrorist organizations and partnering with drug‑trafficking groups such as Tren de Aragua and the Sinaloa Cartel—linking senior Venezuelan officials to organized crime and international drug networks [4]. That designation combines narcotics and counter‑terrorism authorities (E.O. 13224/E.O. 14059) to describe a hybrid illicit‑finance and criminal support infrastructure [4] [1].
4. How OFAC identified targets: legal authorities, evidentiary channels, and public notices
OFAC’s identifications draw on a matrix of statutory and executive authorities—E.O. 13850, 13884, 14059, and 13224 among others—that permit designations for operating in Venezuela’s oil sector, engaging in corruption, facilitating narcotics, or materially supporting terrorist or criminal groups [5] [10] [4]. The agency publishes press releases, Federal Register notices, and SDN entries to name individuals, list dates/identifiers, and describe the predicate conduct [7] [8] [6]. Practically, OFAC relies on financial forensics, maritime tracking (shadow‑fleet movement and AIS manipulation highlighted by shipping data), and interagency intelligence to link tankers and companies to sanctioned activity [3] [9].
5. Enforcement patterns, carve‑outs, and contested moves
Sanctions have targeted roughly 151 Venezuelans and multiple entities under these authorities as part of an evolving campaign to choke illicit finance, with OFAC also issuing general licenses and occasionally removing or relisting individuals to pursue diplomatic aims—Carlos Erik Malpica Flores’ prior designation and later removal to facilitate negotiations is an explicit example cited by Treasury [5] [1]. Critics argue sanctioning shipping intermediaries and broad oil‑sector actors risks collateral economic and humanitarian effects, and OFAC’s FAQ and general‑license framework underscore efforts to allow humanitarian trade while enforcing prohibitions on sanctioned persons [11] [6].
6. Bottom line: targeted persons and the identification method
The roster of sanctioned Venezuelan individuals and networks spans the Maduro family and their business associates (e.g., nephews, Malpica, Carretero), oil traders and shadow‑fleet shipping firms, and organized criminal entities such as Cartel de los Soles—each identified through a combination of executive sanctions authorities, published SDN/Federal Register notices, maritime and financial intelligence, and Treasury’s public explanations of the predicate conduct [2] [1] [3] [4] [7]. Reporting and OFAC materials make clear the U.S. approach couples legal designations with operational information on oil flows, shipping, and money movement to isolate illicit finance tied to the Maduro regime [9] [3] [5].