The principal actors designated today include Alessandro Bazzoni (Bazzoni), Francisco Javier D’Agostino Casado (D’Agostino), Philipp Paul Vartan Apikian (Apikian), Elemento Ltd (Elemento), and Swissoil Trading SA (Swissoil). Bazzoni, along with D’Agostino, is a core facilitator of the network, connecting Elemento and Swissoil with PdVSA and Saab. Bazzoni, an Italian citizen, has been instrumental in coordinating the purchase and sale of Venezuelan-origin crude oil from PdVSA. Following Saab’s June 2020 arrest in Cape Verde and OFAC’s designation of Leal, Bazzoni took over the core coordinating role in the ongoing scheme to broker the re-sale of Venezuelan-origin crude oil from PdVSA and charter vessels willing to go to Venezuela to load oil. Bazzoni was designated today for operating in the oil sector of the Venezuelan economy and because he has materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, PdVSA.
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).
