Omar Jose Prieto Fernandez (Prieto) is the Governor of Zulia State, Venezuela, a position he has held since December 2017. Zulia, located in northwestern Venezuela on the border with Colombia, is known as a hub for organized crime, where narcotics trafficking and murder-for-hire is commonplace. Sophisticated and prolific criminal structures exist throughout Zulia State, penetrating even the border police force under Prieto’s governorship, as several border police officers and the local Zulia police unit have come under investigation for their roles in drug and illegal weapons trafficking. As the Venezuelan people suffer from a lack of access to daily essentials, on February 12, 2019, Prieto threatened to visit the homes of opposition leaders who permitted access to humanitarian aid in Venezuela. Additionally, in response to mass protests, Prieto recently threatened to declare Venezuela’s “oil state” of Zulia independent should a new transition government take power in Venezuela. Known for its massive oil fields below Lake Maracaibo, Zulia is amongst the highest energy-consuming states in Venezuela, but has been experiencing severe electricity shortages, leading to electricity rationing in the midst of the ever-worsening humanitarian crisis.
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).
