Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

Venezuela VE

Domains (D1–D6)

Sources

Role actions

Jurisdiction profile

Grey-ListTier ARisk: IncreasingPermissive

Venezuela remains on the FATF grey list under a CFATF-monitored action plan (high-level commitment June 2024); its 2022 CFATF MER found widespread technical and effectiveness deficiencies across BO transparency, FIU capacity, ML/TF prosecution, NPO oversight and TFS implementation.

The January 2026 capture of Nicolás Maduro and installation of Delcy Rodríguez has opened a rapid, still-unstable transition period marked by cascading OFAC general licenses reopening oil, gold/mineral and financial-services sectors, while state architecture enabling gold smuggling, dark-fleet oil evasion and TCO financing remains largely intact.

Key deficiencies

Beneficial ownership information not adequately, accurately or timely accessible
FIU resourcing and independence still developing despite recent reforms
Weak investigation/prosecution track record for ML and TF offences
NPO sector oversight assessed by FATF as disproportionate/non-risk-based, itself a TF-abuse-mitigation gap
TFS for TF and PF not implemented without delay
Legacy dark-fleet, gold-smuggling and shell-company infrastructure built under Maduro-era sanctions evasion persists structurally despite the leadership change

Recent developments (18m)

Nicolás Maduro captured by US forces in Operation Absolute Resolve (3 January 2026) and rendered to the US on narco-terrorism charges; Delcy Rodríguez sworn in as acting president
CFATF 3rd Enhanced Follow-Up Report (2025) re-rated several Recommendations, noting FIU independence/security improvements but persistent NPO and BO gaps
EU added Venezuela to its high-risk third-country AML/CFT list in June 2025 (Delegated Regulation amending 2016/1675)
Cascading OFAC general licenses (Feb-June 2026) reopening oil, gas, gold/minerals, financial-services and debt-restructuring transactions with the Government of Venezuela and PdVSA
State Department designation of Tren de Aragua as a Foreign Terrorist Organization/SDGT (February 2025) with multiple follow-on OFAC designations of members and a money-laundering network (December 2025)
Delaware court-ordered CITGO/PDV Holding auction concluded with Amber Energy (Elliott affiliate) winning bid (November 2025) to satisfy ~$20 billion in creditor judgments

Brief

Lead signal

Lead Signal

Read full brief

Lead Signal

The dominant financial-integrity signal on Venezuela this cycle is administrative rather than legislative: OFAC's Venezuela-Related Sanctions program index was re-stamped with a Program Last Updated marker of 28 September 2026, reflecting a run of General Licence amendments issued through the month rather than a new instrument. General Licence 5Z, issued 16 September 2026, further delays the effectiveness of General Licence 5 to 5 November 2026. General Licences 5X and 5Y were formalised in the Federal Register on 23 September 2026. General Licence 52C, dated 14 September 2026, narrows and expands PDVSA-contract signing authority within the sanctions program. None of these amendments touches the base executive-order architecture (EO 13692, 13808, 13827, 13850 and 13884), which remains formally in force. The result is a two-track regime: staged, broadening relief for US persons operating around Venezuelan state counterparties, running alongside an explicit, continuing bar on petro-denominated settlement that the licence series has not disturbed. This is a structural reading, not an incident: the substance of the US posture toward Venezuela is being written through licence-by-licence administration of an architecture that itself has not moved.

Read against FATF's most recent plenary statement, of 19 June 2026, Venezuela remains under increased monitoring, with deficient and inaccessible beneficial-ownership information named as an open action-plan item. No subsequent plenary outcome was located inside this cycle's window; the next scheduled plenary falls around October 2026. The persistence of a grey-list designation alongside an active, moving US licensing track is itself a finding: enforcement posture and bilateral commercial accommodation are proceeding on separate, only loosely coordinated timelines.

Other Developments

A sentencing in Miami illustrates enabler-jurisdiction exposure inside the United States itself. Former US Congressman David Rivera was sentenced on 2 October 2026 to ten years imprisonment, with forfeiture of Florida real property, for covert, undisclosed lobbying conducted in 2017-2018 on behalf of Venezuela's PSUV government. The arrangement ran through a USD 50 million consulting contract tied to then-Foreign Minister Delcy Rodriguez, who now holds Venezuela's acting presidency. The case rests on quality-journalism reporting rather than a located primary Department of Justice release this cycle, and is carried at probable rather than confirmed confidence on that basis. Architecturally, the case is significant less for its individual facts than for what it demonstrates about enabler-jurisdiction analysis: the channel exploited for years was the United States' own political-consulting and lobbying infrastructure, not an offshore secrecy jurisdiction. An enabler-jurisdiction read of Venezuela-linked influence financing cannot stop at the periphery.

The PDVSA-Cripto trial continues in Caracas with the regulatory vacuum it exposed still unfilled. Proceedings against more than fifty defendants tied to the 2023 collapse of the state crypto regulator SUNACRIP continued this cycle, with official loss estimates of USD 5.55 billion sitting against independent estimates running from USD 16.9 billion to USD 23 billion. No successor regulatory agency has been formally established. The claim rests on a single Tier 4 vendor source this cycle; no primary SUNACRIP or prosecutorial text was retrieved, and the finding is held at probable confidence accordingly. The persistence of the gap itself, nineteen months after the collapse it followed, is the structural point: an institutional void in digital-asset oversight has now outlasted the scandal that created it.

Cross-Monitor Connections

The sanctions-licence track intersects directly with the crypto monitor's cross-border-transfer findings: General Licence 52C's continuing exclusion of petro-denominated settlement, and General Licence 5Z's further delay of General Licence 5's effectiveness, are the same instruments that define the operative cross-border crypto corridor for Venezuela, meaning the US sanctions architecture functions as the de facto digital-asset settlement regime in the absence of a functioning domestic licensing authority. The PDVSA-Cripto trial's continuation without a successor regulator is similarly a shared finding across the sanctions and digital-asset lenses: a conflict-finance and extractive-industry integrity reading of the same institutional vacuum would ask what fills the supervisory space SUNACRIP vacated, a question this cycle's evidence base does not yet answer. The Rivera sentencing, while a US domestic criminal matter, routes naturally to any monitor tracking state-capture-adjacent influence financing, given the PSUV-government nexus and the acting-president connection.

Outlook

The near-term marker to watch is the FATF plenary expected around October 2026, which will either confirm Venezuela's continued increased-monitoring status or register movement on the beneficial-ownership deficiency flagged in June 2026. On the sanctions track, General Licence 5's delayed effectiveness date of 5 November 2026 is itself a date to track: a further delay would extend the current two-track pattern, while allowing the licence to take effect as scheduled would mark the first concrete narrowing of the staged-relief sequence seen since September. Absent a new primary instrument, expect continued administration-by-licence of the existing architecture rather than a change to the underlying EO framework.

weekly_brief_draft · JID VE

Domain intelligence (D1–D6)

D1 Sanctions Architecture and Evasion

Sanctions Architecture and Evasion

The operative Venezuela sanctions story this cycle is administrative movement inside a stable architecture. OFAC's Venezuela-Related Sanctions program page carries a Program Last Updated stamp of 28 September 2026, reflecting a run of General Licence amendments through September rather than any new primary instrument. General Licence 5Z, issued 16 September 2026, further delays the effectiveness of General Licence 5 to 5 November 2026. General Licences 5X and 5Y were formalised in the Federal Register on 23 September 2026. General Licence 52C, dated 14 September 2026 and replacing General Licence 52B, continues to narrow and expand PDVSA-contract signing authority. The base executive-order architecture, EO 13692, 13808, 13827, 13850 and 13884, remains formally in force throughout; nothing this cycle amends the comprehensive-sanctions designation itself.

The structurally significant feature is the two-track character of the regime that this staged licensing produces. On one track, the licence series is broadening the scope for US-person engagement with Venezuelan state counterparties, consistent with a posture of gradual commercial reintegration. On the other, General Licence 52C's text continues to bar settlement in digital currency, coin or tokens issued by or for the Government of Venezuela, an explicit and continuing prohibition that the relief track has not touched. Architecture-over-incident framing applies directly here: the individual licence amendments are not, on their own, the finding. The finding is that the underlying sanctions programme is being administered through a sequence of licence-level adjustments rather than through amendment of the base designation, and that the digital-currency settlement bar has proven durable across every amendment in the sequence retrieved this cycle.

Against this US track, Venezuela's FATF status provides an independent, slower-moving axis. The 19 June 2026 plenary statement places Venezuela under increased monitoring, with deficient and inaccessible beneficial-ownership information recorded as an open action-plan item tied to Recommendation 24. No subsequent plenary outcome was located inside this cycle's window; the next scheduled plenary falls around October 2026. The grey-list designation and the US licensing track are not coordinated instruments, and nothing in the evidence base this cycle suggests that US relief measures or FATF monitoring status are each responding to the other. That non-coordination is itself the structural read for compliance teams: a jurisdiction's commercial accessibility under one regime's licensing framework is not a signal about its AML/CFT standing under another, and the two tracks should be assessed independently rather than as a single trajectory.

Outlook

The clearest near-term marker is the effectiveness date General Licence 5Z has fixed for General Licence 5: 5 November 2026. Whether that date holds, or is itself delayed by a further amendment, will indicate whether the staged-relief sequence is approaching a settled state or remains in continuous administrative motion. Separately, the FATF plenary expected around October 2026 is the marker to watch on the AML/CFT axis; it may confirm continued increased monitoring or register movement on the beneficial-ownership deficiency identified in June. Firms with Venezuela exposure should treat the digital-currency settlement bar in General Licence 52C as a stable feature of the architecture rather than a candidate for near-term relief, given its persistence across every amendment in this cycle's sequence.

D2 Beneficial Ownership

Not covered

Beneficial Ownership is not yet covered for this jurisdiction in this report.

D3 Enabler Jurisdictions and Professional Facilitators

Enabler Jurisdictions and Professional Facilitators

The sentencing of former US Congressman David Rivera on 2 October 2026 is this cycle's clearest enabler-jurisdiction finding, and it is notable for where it locates the enablement: inside the United States' own political and lobbying infrastructure, not in an offshore secrecy jurisdiction conventionally associated with facilitation risk. Rivera, together with co-defendant Esther Nuhfer, was convicted of secretly working from 2017 to 2018 for Venezuela's PSUV government through a USD 50 million consulting contract tied to then-Foreign Minister Delcy Rodriguez, who has since become Venezuela's acting president. The sentence carries ten years imprisonment plus forfeiture of Florida real property. The finding rests on corroborating quality-journalism reporting rather than a located primary Department of Justice release this cycle, and is held at probable rather than confirmed confidence on that basis.

FIM's enabler-jurisdiction doctrine holds that a jurisdiction is judged by what its professional and institutional infrastructure permits as much as by what it ultimately enforces against. The Rivera case is a direct illustration: the lobbying and consulting channel used to advance PSUV interests operated for roughly two years, through a well-regulated financial centre's own political-consulting ecosystem, before FARA enforcement caught up with it. The case does not indicate a defect in US law on its face; the relevant disclosure framework existed throughout. What it demonstrates is a gap between the existence of a disclosure regime and its real-time operation against a sophisticated, well-connected facilitator. That gap, rather than the individual sentencing outcome, is the structurally significant point: enabler-jurisdiction risk assessment that focuses only on jurisdictions with weak disclosure frameworks on paper will miss facilitation that runs through jurisdictions with strong frameworks that were, in practice, circumvented for an extended period.

The acting-president connection sharpens the significance further. A contract structured around a minister who has since ascended to Venezuela's acting presidency means the facilitation channel at issue was not peripheral to the PSUV government's interests but ran close to its centre. For institutions assessing PEP-adjacent exposure connected to current Venezuelan state officials, the case is a reminder that influence-financing channels uncovered years after the fact can implicate individuals who have since moved to more senior positions, widening the retrospective PEP-nexus question beyond whoever held office at the time the underlying conduct occurred.

Outlook

No further developments in the Rivera matter, such as appeal proceedings or related civil forfeiture actions, were located this cycle; subsequent reporting on sentencing implementation and asset forfeiture execution would be the next markers to track. More broadly, the case argues for continued attention to the enabler-jurisdiction question inside well-regulated centres themselves, including the United States, rather than treating enabler-jurisdiction risk as a category that applies principally to jurisdictions with permissive disclosure regimes on their face.

D4 Conflict Finance

Not covered

Conflict Finance is not yet covered for this jurisdiction in this report.

D5 Crypto, Digital Assets, and Financial Innovation

Crypto, Digital Assets, and Financial Innovation

The PDVSA-Cripto trial continued in Caracas this cycle, with proceedings against more than fifty defendants still tied to the 2023 collapse of the state crypto regulator SUNACRIP. Official estimates place the embezzlement at USD 5.55 billion; independent estimates range from USD 16.9 billion to USD 23 billion, a spread wide enough that the two figures describe materially different scales of loss. No successor regulatory agency has been formally established in the nineteen months since the collapse. The finding rests on a single Tier 4 vendor source this cycle, with no primary SUNACRIP or prosecutorial text retrieved to corroborate it, and is accordingly held at probable rather than confirmed confidence.

The structural significance of this development is the persistence of the regulatory vacuum itself, which has now outlasted the scandal that created it. A digital-asset ecosystem that functioned, however imperfectly, under a named state regulator has operated for a year and a half with no replacement supervisory authority, no stated transition plan, and no located institutional signal of what, if anything, fills SUNACRIP's former mandate over exchanges, miners and brokers. Architecture-over-incident framing applies squarely here: the trial's individual proceedings are secondary to the fact that the institutional space they exposed remains empty. That absence is itself analytically significant rather than a mere data gap, and it bears directly on how any Venezuela-linked digital-asset activity should be read: the state has not re-asserted licensing authority, which leaves exchanges, custodial platforms and mining operations with no current domestic regulatory counterparty to account to.

The widening gap between official and independent loss estimates is a second point worth isolating. A near-threefold divergence between the two figures suggests either that the official estimate reflects only a narrower slice of the conduct under prosecution, or that independent reporting has captured categories of loss the official figure excludes. Neither possibility can be resolved from this cycle's evidence base, and the gap itself, rather than either figure individually, is the fact that should inform exposure assessments: institutions with historical Venezuela-linked crypto counterparty relationships predating 2023 face a materially uncertain range of associated loss, not a settled figure.

Outlook

The principal marker to watch is any verdict in the PDVSA-Cripto proceedings, which would be the first concrete resolution point since the trial's continuation was last confirmed. A verdict, when it arrives, may also clarify which of the two loss-estimate figures the judicial record ultimately supports. Separately, any announcement of a successor regulatory body to SUNACRIP would be a structurally significant development in its own right, given how long the vacancy has now persisted; its continued absence should be read as a standing condition rather than a temporary gap pending near-term resolution.

D6 Compliance Technology & Active Defence

Not covered

Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.

D7 AML/CTF Regime

Not covered

AML/CTF Regime is not yet covered for this jurisdiction in this report.

D8 Commercial Activity

Not covered

Commercial Activity is not yet covered for this jurisdiction in this report.

Regulatory horizon

No dated horizon items this cycle. 4 items tracked without a confirmed date.

4 pending date · baseline fim-2026-07-06

Role action cards

MLRO

OFAC re-stamped the Venezuela sanctions program index on 28 September 2026 following a run of General Licence amendments, while the petro-denominated settlement bar persists unchanged.

Screening logic keyed to the base EO architecture remains valid, but licence-level exceptions affecting correspondent and PDVSA-contract counterparties have moved and should be re-checked against the current licence set rather than the prior one.

2 evidence refs

Compliance

Venezuela remains under FATF increased monitoring per the 19 June 2026 plenary statement, with deficient beneficial-ownership access still an open action-plan item.

Enhanced due diligence posture tied to FATF grey-list status should be maintained pending the next plenary outcome, expected around October 2026; no change to the designation basis is confirmed this cycle.

1 evidence refs

Legal

A Miami sentencing demonstrates FARA enforcement reaching a years-old covert lobbying arrangement tied to Venezuela's PSUV government and its now-acting president.

The case illustrates that undisclosed foreign-agent lobbying exposure can surface years after the underlying conduct, with sentencing and forfeiture outcomes relevant to any related civil exposure assessment for US-domiciled intermediaries.

1 evidence refs

Board

US unilateral relief on Venezuela continues to expand through staged licensing while the underlying sanctions designation remains unchanged.

Strategic exposure to Venezuela-linked counterparties should be assessed against the stable base architecture rather than the more fluid licence-level relief track, which has shown repeated amendment through this cycle.

1 evidence refs

CTO

The PDVSA-Cripto trial continues with no successor crypto regulator established nineteen months after SUNACRIP's collapse.

Any platform architecture with historical Venezuela crypto-counterparty touchpoints operates against a domestic regulatory vacuum, with loss estimates for the underlying scandal ranging widely between official and independent figures.

1 evidence refs

Risk

A near-threefold gap between official (USD 5.55bn) and independent (USD 16.9-23bn) PDVSA-Cripto loss estimates remains unresolved this cycle.

Exposure models relying on a single loss figure for historical Venezuela crypto-sector counterparty risk should account for this unresolved range rather than anchoring to either estimate alone.

1 evidence refs

Operations

Staged OFAC General Licence amendments (5Z, 5X/5Y, 52C) through September 2026 change the operative screening parameters for Venezuela-linked transactions.

Transaction-screening rule sets referencing prior licence versions should be updated to the current amendment set, particularly the 5 November 2026 effectiveness date for General Licence 5 as delayed by 5Z.

2 evidence refs

Audit

The Rivera sentencing and the PDVSA-Cripto trial both rest partly on secondary-source reporting this cycle, with no primary DOJ or SUNACRIP text independently retrieved.

Audit trails referencing either development should note the underlying confidence tier as probable rather than confirmed, pending retrieval of primary documentary sources.

2 evidence refs

Decision lens

MLRO

OFAC re-stamped the Venezuela sanctions program index on 28 September 2026 following a run of General Licence amendments, while the petro-denominated settlement bar persists unchanged.

Compliance

Venezuela remains under FATF increased monitoring per the 19 June 2026 plenary statement, with deficient beneficial-ownership access still an open action-plan item.

Legal

A Miami sentencing demonstrates FARA enforcement reaching a years-old covert lobbying arrangement tied to Venezuela's PSUV government and its now-acting president.

Board

US unilateral relief on Venezuela continues to expand through staged licensing while the underlying sanctions designation remains unchanged.

CTO

The PDVSA-Cripto trial continues with no successor crypto regulator established nineteen months after SUNACRIP's collapse.

Risk

A near-threefold gap between official (USD 5.55bn) and independent (USD 16.9-23bn) PDVSA-Cripto loss estimates remains unresolved this cycle.

Operations

Staged OFAC General Licence amendments (5Z, 5X/5Y, 52C) through September 2026 change the operative screening parameters for Venezuela-linked transactions.

Audit

The Rivera sentencing and the PDVSA-Cripto trial both rest partly on secondary-source reporting this cycle, with no primary DOJ or SUNACRIP text independently retrieved.

Shared evidence: 3 refs

Scenario sketches

AMLA transition and cross-border supervisory reach

An illustrative orientation only: as the AMLA Regulation (Reg (EU) 2024/1620) moves EU supervision of cross-border obliged entities from purely national authorities toward a hybrid EU-level regime, alongside the directly-applicable AMLR (Reg (EU) 2024/1624) and per-state 6AMLD transposition, the supervisory perimeter facing entities with non-EEA exposure, such as correspondent relationships touching Venezuela-linked sanctioned-party risk, could shift. A possible structural mechanism is that EU-domiciled obliged entities with Venezuela-linked correspondent exposure face a single supervisory counterparty for cross-border risk assessment rather than a patchwork of national regulators, potentially changing how sanctions-nexus findings routed through EU institutions are reported and escalated. This is illustration of a possible structural mechanism, not an observed fact or a prediction.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)

Tracker	Status	Note
T1 · Russian Sanctions-Evasion Architecture	no_change	No material VE-specific movement in Russian dark-fleet, tech-procurement or commodity-rerouting channels this cycle.
T2 · EU AML Package / AMLA	no_change	VE is outside the EEA/AMLR/6AMLD/AMLA perimeter; no change to the instruments themselves affects VE directly this cycle.
T3 · FATF Grey List	no_change	VE remains under FATF increased monitoring per the 19 June 2026 plenary statement; no subsequent plenary outcome located this cycle.
T4 · Beneficial-Ownership Register Status	no_change	No BO-registry development for VE located this cycle; FATF continues to flag deficient, inaccessible BO information.
T5 · Crypto & Digital-Asset Integrity	watch	PDVSA-Cripto trial of over 50 defendants continued in Caracas; no successor crypto regulator formally established; loss estimates range USD 5.55bn (official) to USD 16.9-23bn (independent).
T6 · Sanctions Regime Divergence	watch	US unilateral relief continues to diverge sharply from EU/UK posture on VE; OFAC issued further amended GL and FAQ 28 Sep 2026 with no corresponding EU/UK delisting action identified.

Registers

Enforcement actions

OFAC designated four Hong Kong/mainland China-based shell companies and four connected vessels (Della, Nord Star, Rosalind, Valiant) for evading Venezuelan oil-sector sanctions as part of an escalating pressure campaign against Maduro-regime oil exports. 31 Dec 2025
Following the February 2025 FTO/SDGT designation of Tren de Aragua, OFAC sanctioned top gang leaders (Hector 'Nino Guerrero' Guerrero Flores and others, July 2025) and, in December 2025, a broader money-laundering network including individuals and a Colombian entertainment-sector shell company supporting the group's finances. 3 Dec 2025
OFAC updated the SDN list on 1 April 2026 to remove Delcy Rodriguez as a Venezuela-program designation (reflecting her post-Maduro role as acting president), while separately maintaining/adding designations against Panama-based individuals (Roberto and Vicente Luis Carretero Napolitano) linked to Government of Venezuela asset concealment under the VENEZUELA-EO13850 program. 1 Apr 2026
CFATF's 3rd Enhanced Follow-Up Report (adopted with technical compliance re-ratings, reflecting progress to December 2025) assessed Venezuela's implementation of its Fourth Round MER recommended actions, finding some criteria met (e.g., Recommendation 2 national coordination) but continued deficiencies in beneficial ownership and NPO oversight. 1 Dec 2025
US special forces captured former President Nicolás Maduro and his wife in a raid (Operation Absolute Resolve) after prior narco-terrorism indictments, rendering him to the United States to face criminal charges including narcotics trafficking and corruption-linked financial crime allegations. 3 Jan 2026

Sanctions changes

Following Maduro's capture, OFAC issued a cascade of new Venezuela-related general licenses reopening oil/gas sector operations (GL 46C, 50B), gold/minerals trade (GL 51B, 54A, 55), financial-services transactions with Venezuelan banks and GoV individuals (GL 57), debt-restructuring services (GL 58) and contingent-contract negotiations for investment (GL 49A, 56), fundamentally restructuring the sanctions architecture from comprehensive blocking toward managed re-engagement. 10 Jun 2026
The EU Council renewed its Venezuela restrictive-measures regime (arms embargo, travel bans and asset freezes on 69 individuals) for a further year to 10 January 2027, maintaining the human-rights/rule-of-law-based sanctions architecture in place since November 2017 despite the change in Caracas leadership. 15 Dec 2025
The European Commission added Venezuela to its EU high-risk third-country AML/CFT delegated-regulation list in the June 2025 update, requiring EU-regulated entities to apply enhanced customer due diligence to Venezuela-linked transactions and relationships. 10 Jun 2025
OFAC removed Delcy Eloina Rodriguez Gomez from the Venezuela-program SDN list (1 April 2026), reflecting her transition from a sanctioned Maduro-regime official to the US-recognized transitional leadership counterpart following Maduro's capture. 1 Apr 2026

Regulatory horizon (register)

FATF October 2026 plenary review of Venezuela action plan
PdVSA 2020 8.5% bond GL 5X wind-down/CITGO-share litigation deadline
Venezuela PNAP 2024-2026 AML/CFT/CPF national action plan completion
EU Council review of Venezuela restrictive measures ahead of January 2027 expiry

Active schemes

[CRITICAL] Dark-fleet oil tanker network evading US crude sanctions
[CRITICAL] Conflict-linked gold smuggling via Orinoco Mining Arc
[HIGH] PDVSA stablecoin (USDT) settlement to bypass bank sanctions
[CRITICAL] Tren de Aragua transnational money-laundering network
[HIGH] Panama/Colon shell-company network for GoV asset concealment

Sources

Coverage gaps

Despite CFATF re-ratings on some technical-compliance criter…

Despite CFATF re-ratings on some technical-compliance criteria, Venezuela's FATF action plan flags persistent failure to ensure beneficial ownership information is adequate, accurate and accessible in a timely manner -- a foundational gap enabling shell-company layering by state and non-state actors alike.

Global Witness satellite monitoring found extensive oil-slic…

Global Witness satellite monitoring found extensive oil-slick pollution (over 10,400 km² detected in Lake Maracaibo alone since January 2025) and irregular-mining-driven deforestation in the Orinoco Mining Arc continuing to expand even as OFAC licenses reopen extractive-sector investment, with no domestic environmental or beneficial-ownership disclosure regime to accompany the reopening.

The abrupt, US-driven leadership transition (Maduro's captur…

The abrupt, US-driven leadership transition (Maduro's capture and Rodríguez's ascension) has produced no announced dismantling of the repressive state apparatus or the financial architecture that sustained sanctions evasion; UN human rights investigators reported 87 new politically motivated detentions since the capture despite roughly 100+ political-prisoner releases.

No public evidence was found in this research window of Vene…

No public evidence was found in this research window of Venezuela adopting or mandating RegTech/AI-driven transaction-monitoring or perpetual-KYC supervisory expectations for its banking or virtual-asset sectors; SUDEBAN's March 2025 resolution establishes baseline AML/CFT/CPF policy-setting authority but no forward-looking compliance-technology mandate was identified.

Evidence

Confidence-tiered claims

Venezuela-Related Sanctions program page shows a 'Program Last Updated' stamp of 28 Sep 2026 SRC-fim-VE-001

Probable · 1 source

10 years imprisonment plus forfeiture of Florida real property for covert, undisclosed lobbying (2017-2018) on behalf of Venezuela's PSUV government via a USD 50 million consulting contract tied to then-Foreign Minister Delcy Rodriguez SRC-fim-VE-005

Probable · 1 source

Over 50 defendants on trial in Caracas tied to SUNACRIP's 2023 collapse; no successor crypto regulator formally established; estimated embezzlement USD 5.55bn (official) to USD 16.9-23bn (independent) SRC-fim-VE-006

Probable · 1 source

Venezuela remains under FATF increased monitoring per the 19 June 2026 plenary statement; deficient, inaccessible beneficial-ownership information flagged as an open action-plan item SRC-fim-VE-004

Probable · 1 source

GL 52C (14 Sep 2026) narrows/expands PDVSA-contract signing authority within the Venezuela sanctions program SRC-fim-VE-002

Confirmed · 1 source