The Treasury’s Office of Foreign Assets Control’s recent action of sanctioning Evrofinance -- a Russian bank the U.S. suspects of working with the Venezuelan government -- was a two-part warning to Venezuela, the Kremlin and others, trade lawyer and former OFAC senior sanctions policy adviser Michael Dobson said in an interview. The U.S. will not hesitate to tighten restrictions on Venezuela, Dobson said, and it does not feel constrained to sanction “outside actors” assisting the Nicolas Maduro regime. The sanction (see 1903110014), announced in a March 11 OFAC notice, will be published in the March 22 Federal Register. Dobson, now a lawyer at Morrison Foerster, said he suspects Evrofinance of being a “very narrow vehicle” set up by Russia and Venezuela to facilitate trade and to “release some of the pressure from the Maduro regime's decreasing access to U.S. dollars.” The action will likely not become a trend for Venezuela, Dobson said, but a stand-alone action wherein the U.S. was able to enforce evasions of sanctions. “I think it’s just a warning,” Dobson said, adding that as long as U.S. companies aren’t doing business with Venezuela or Evrofinance, “I don't think this is going to have significant ripple effects.”
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