Last week, Cuban Vice President Ramiro Valdes was appointed to a senior position in Venezuelan government. The problem is, Valdes, (believed to rank third in the Government of Cuba, right behind the Castro brothers) is only one of an estimated 80,000 Cuban nationals assisting in the operation of much of Venezuela's key industries, as well as help run their government. What dies this mean for US financial institutions ? Your bank clients may be unwittingly conducting transactions with Cuban PEPs, Cuban nationals seconded to government-controlled industry, or even members of the Cuban military officer corps, who now reportedly command major Venezuelan army units. Will OFAC levy fines & penalties against your clients, and are do your wire transfers to Venezuela violate sanctions when the individual who signed the contract happens to be a Cuban PEP ?

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