Sanctions in Latin America

One important conclusion about the way sanctions are working in the LAC region is that companies need to keep abreast of what can often be fast-moving changes to sanction coverage, definition, and enforcement. One example of what can be at stake came in May 2022 when Banco Popular de Puerto Rico (BPPR) said it had paid US$255,938 to OFAC to settle a sanctions violation case. OFAC said BPPR failed to adequately implement the new Venezuela-related sanctions introduced in August 2019 (see Venezuela timeline). As a result, the bank provided account services to two relatively low-level Venezuelan government employees. It supported 337 transactions over a 14-month period, moving a total of US$852,126. This was done despite the bank having earlier acknowledged the changes, which were contained in EO13884 and which among other things seek to block all Venezuelan government property and related assets under US jurisdiction.

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