OFAC also designated three other individuals for being current or former officials, or for acting for or on behalf of designated individuals as key figures in Cabello’s corruption network. Those individuals are José David Cabello Rondón, Cabello’s brother, designated for being a current or former official of the Government of Venezuela; Marleny Josefina Contreras Hernández, Cabello’s wife, designated for being a current or former official of the Government of Venezuela; and Rafael Alfredo Sarria Diaz, Cabello’s front man (“testaferro”), designated for acting for or on behalf of Cabello. José David Cabello Rondón (José David) is the current Superintendent of the Servicio Nacional Integrado de Administracion Aduanera y Tributaria, or the National Integrated Customs and Tax Administration (SENIAT). He previously served as the Minister of Infrastructure and the Minister of Popular Power for Industries. José David has used his access as the head of the Venezuelan Tax and Customs agency to extort money for personal gain from Venezuelans. As of late 2017, Cabello, in his role as the First Executive Vice-President of the PSUV, and José David as the head of the SENIAT, were the main beneficiaries of extortion schemes against domestic and foreign private companies. The brothers shared a percentage of the extortion proceeds with other ministers and officials in Maduro’s inner circle. A typical extortion scheme involved SENIAT officials auditing a business and identifying both actual and falsified irregularities. The SENIAT officials would then give the business the option to pay a single large fine to SENIAT or a smaller fine to SENIAT with a smaller kickback to the officials. The companies would then log the kickbacks as business transactions. SENIAT officials increasingly have the kickbacks paid to specifically established, temporary Venezuelan bank accounts for fear of U.S. financial sanctions levied against senior officials and to avoid increased scrutiny of foreign bank accounts.
On July 10, 2015, OFAC issued the Venezuela Sanctions Regulations, 31 CFR part 591 (the ‘‘Regulations’’) (80 FR 39676, July 10, 2015) to implement the Venezuela Defense of Human Rights and Civil Society Act of 2014 (Pub. L. 113– 278) and Executive Order 13692 of March 8, 2015 (‘‘Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela’’) (E.O. 13692). The Regulations were published in abbreviated form for the purpose of providing immediate guidance to the public. Since then, the President has issued six additional Executive orders pursuant to the national emergency declared in E.O. 13692: Executive Order 13808 of August 24, 2017 (‘‘Imposing Additional Sanctions With Respect to the Situation in Venezuela’’) (82 FR 41155, August 29, 2017); Executive Order 13827 of March 19, 2018 (‘‘Taking Additional Steps to Address the Situation in Venezuela’’) (83 FR 12469, March 21, 2018); Executive Order 13835 of May 21, 2018 (‘‘Prohibiting Certain Additional Transactions With Respect to Venezuela’’) (83 FR 24001, May 24, 2018); Executive Order 13850 of November 1, 2018 (‘‘Blocking Property of Additional Persons Contributing to the Situation in Venezuela’’) (83 FR 55243, November 2, 2018); Executive Order 13857 of January 25, 2019 (‘‘Taking Additional Steps To Address the National Emergency With Respect to Venezuela’’) (84 FR 509, January 30, 2019); and Executive Order 13884 of August 5, 2019 (‘‘Blocking Property of the Government of Venezuela’’) (84 FR 38843, August 7, 2019).
