Selective Selection to Sanctions List to Sow Suspicion

According to a story by Franco Ordonez, the United States has been selectively using its sanctions regime in Venezuela in an effort to destabilize the government.

“For over a year, Diosdado Cabello, the former military commander and vice president of Venezuela’s governing United Socialist Party, escaped sanctions that hit more than 50 other Venezuelan officials, including [President] Maduro, on corruption and other charges.”

The plan was to plant seeds in Venezuela that Cabello was taking to the United States or, worse, acting as agent of the US. The plan was eventually abandoned after Senator Rubio pressed the administration to subject Cabello to sanctions.

I find this story interesting from a diplomatic perspective, but troubling from an ALM/KYC perspective.

That period of time where a foreign person should have been on the sanctions list, but was not placed due to some Washington trickery, means that companies may have been doing business with him. When he is suddenly added to the list, those companies are then in trouble.

Of course, he likely would have been identified as Politically Exposed Person. But that just means caution, not a ban on a business relationship.

What may have been a fun exercise for Foggy Bottom spies, creates a minefield for ALM/KYC practitioners.

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