Nelson Reinaldo Lepaje Salazar (Lepaje) is acting in the capacity of the Head of the Office of the National Treasury of Venezuela. Lepaje was formerly delegated the functions of the Assistant National Treasurer, and in that role he was involved in oversight of administrative procedures and the signing of official documents, including financial agreements between the Ministry of Popular Power, the Central Bank of Venezuela, and any national or foreign financial institutions that are auxiliary entities of the National Treasury Office. Lepaje also authorized the opening of bank accounts with funds from the National Treasury in both national and foreign currencies. The former National Treasurer, Carlos Erick Malpica Flores, also was designated by OFAC, in July 2017. In addition, the Venezuelan National Treasury has been the subject of previous corruption allegations, as it was alleged that President Maduro stole nearly $10 million from the National Treasury.
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).
