Sanctions in Latin America

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In recent years, sanctions targeting Russia, Iran and North Korea have received significant attention. Yet, some of the longest-standing and most comprehensive sanctions programmes of the US target individuals and governments in Latin America and the Caribbean. Businesses with operations in the Americas must be aware of these risks and design effective compliance programmes to mitigate them.

Companies (and their subsidiaries) operating in Latin America must navigate country-specific sanctions, such as those against Cuba, Venezuela and Nicaragua, and subject matter-related sanctions, such as narcotics trafficking sanctions under the Counter Narcotics Trafficking Sanctions or the Foreign Narcotics Kingpin Designation Act (the Kingpin Act), and human rights sanctions under the Global Magnitsky Human Rights Accountability Act (the Magnitsky Act). It has been said that in Latin America, sanctions have become one of the central pillars of US policy to defend democracy and combat corruption.[2]

As discussed in this chapter, while many sanctions programmes have been consistently in force for years, other aspects of sanctions programmes have diverged between successive US presidential administrations. Legal advisers must maintain awareness of these developments when advising clients.

This chapter surveys trends relating to sanctions targeting Latin America and certain considerations for legal advisers, with a focus on US sanctions. It also discusses certain sanctions programmes enacted by Latin American governments. Sanctions tend to be used by Latin American countries relatively infrequently, perhaps in part due to a history of non-alignment of foreign policy in the region.

Country-specific US sanctions

At the time of writing, three countries in the Latin America region – Cuba, Nicaragua and Venezuela – are targeted by US sanctions. Cuba is subject to the longest-running and broadest set of sanctions. Venezuela is also subject to broad sanctions against its government, whereas sanctions on Nicaragua are targeted and directed solely at certain individuals and government entities.


Since 1962, the US has implemented a comprehensive embargo against Cuba, which is now codified under the Cuban Assets Control Regulations (CACR), at 31 Code of Federal Regulations (CFR) Part 515. The CACR restrict US persons, non-US persons within the US and non-US entities owned or controlled by US persons from trading or engaging in other transactions with Cuba. The CACR are generally maintained and enforced by the US Department of the Treasury’s Office of Foreign Assets Control (OFAC).[3]

The legal basis for restrictions against Cuba dates back to the Trading with the Enemy Act (TWEA) of 1917, which authorised the US President to restrict trade between the US and its enemies in times of war.[4] Determinations of restrictions under the TWEA are made on an annual basis, and in September 2022, President Biden extended TWEA restrictions against Cuba for an additional year.[5] Cuba is currently the only country subject to restrictions under the TWEA. The Foreign Assistance Act of 1961 further barred the US government from providing foreign aid to the government of Cuba and authorised the President to establish and maintain a total embargo on trade between the US and Cuba.[6] The embargo was tightened by the Cuban Democracy Act (CDA) of 1992,[7] which restricted foreign aid to other nations that provided aid to Cuba, and which may be viewed as an early precursor to the use of secondary sanctions.[8] The CDA also enacted sanctions on vessels engaging in trade with Cuba, and authorised donations of food and exports of medicine and medical supplies. The embargo against Cuba was codified by the Cuban Liberty and Democratic Solidarity (LIBERTAD) Act of 1996.[9] The LIBERTAD Act also authorised a private right of action against persons who traffic in property confiscated by the Cuban government on or after 1 January 1959 (though, as discussed below, this provision had no effect until recently), and defined a difficult standard by which the embargo may be lifted. The Trade Sanction Reform and Export Enhancement Act of 2000 authorised certain exports of medical or agricultural goods to Cuba and some related travel and financial transactions under certain conditions.[10]

Although constrained by the parameters of the embargo’s statutory underpinnings, within these limitations, in recent years, US presidential administrations have taken differing approaches to the US relationship with Cuba. In December 2014, the Obama administration announced an intent to re-establish diplomatic relations with Cuba.[11] These changes occurred by way of several rounds of regulatory changes and policy decisions, including prisoner exchanges;[12] easing of travel restrictions; allowing certain remittances;[13] and the authorisation of a limited number of other transactions with Cuba.[14] The administration also rescinded Cuba’s designation as a state sponsor of terrorism.[15] However, the Trump administration reversed and limited some of these changes, beginning in November 2017.[16] Notably, the changes disallowed the ‘U-turn exception’ (which had allowed US financial institutions to process certain US dollar payments relating to Cuba in which both the originator and beneficiary were outside of the US), created a Cuba Restricted List identifying entities determined to support Cuban military or security services with whom persons subject to the jurisdiction of the US are barred from transacting, lowered the de minimis threshold for export controls relevant to Cuba from 25 per cent to 10 per cent, and restricted travel and remittances. Additionally, the Trump administration allowed the previous suspension of the private right of action under Title III of the LIBERTAD Act to lapse, which has allowed a number of lawsuits against persons accused of trafficking in property confiscated by the Cuban government.[17] In January 2021, the Trump administration re-designated Cuba as a state sponsor of terrorism.[18]

As at the time of writing, the only significant change that the Biden administration has made with respect to the Cuba sanctions has been certain amendments to the CACR announced in May 2022.[19] These changes followed a review of US policy towards Cuba and aimed to increase support for the Cuban people by facilitating family reunification, expanding authorised travel, easing restrictions on remittances and supporting Cuba’s private sector. According to a State Department spokesperson, the changes will provide Cubans with ‘additional tools to pursue life free from Cuban government oppression and to seek greater economic opportunities’.[20] Earlier in the Biden administration, in 2021, new sanctions targeting leaders of the Cuban police force were issued in the wake of anti-government demonstrations by the Cuban people protesting the country’s ongoing economic crisis as it was battling the covid-19 pandemic.[21] The Biden administration also met with Cuban officials in Havana on 28 April 2023 to discuss, among other things, the listing of Cuba as a state sponsor of terrorism.[22] The Biden administration has said that it is reviewing Cuba’s status on the terrorism list, but has yet to make any changes. Practitioners should continue to monitor this area for developments.


The Venezuela Sanctions Regulations are maintained at 31 CFR Part 591; they reflect a number of sanctions implemented against Venezuela in recent years. The US implemented broad sanctions against the government of Venezuela in March 2015 in response to human rights violations by the Nicolás Maduro regime and accompanying civil unrest and regime instability.[23] In August 2017, the US prohibited transactions relating to new debt of the state-owned oil company Petróleos de Venezuela, SA (PdVSA) or new debt or equity of the Venezuelan government. Facilitating profit distributions to the Venezuelan government from any entity owned or controlled by the Venezuelan government was also prohibited.[24] In March 2018, the US prohibited transactions involving digital currency, coins or tokens issued by the Venezuelan government.[25] In May 2018, the US prohibited transactions involving debt owed to the Venezuelan government in an effort to reduce public corruption.[26] In January 2019, the US amended previous sanctions to recognise the swearing-in of interim President Juan Guaido and to ensure that earlier sanctions against the ‘Government of Venezuela’ remained focused on the Maduro regime.[27] In August 2019, the US designated the entire Venezuelan government as a Specially Designated National (SDN), broadly defining the government to include many entities sanctioned under previous executive orders, including political subdivisions, the Venezuelan central bank, PdVSA, entities owned by these and any person acting or purporting to act for or on behalf of these entities.[28] Additionally, the Venezuelan gold, defence and security, financial and oil sectors have been targeted for additional sanctions enforcement.[29] In November 2022, the Biden administration eased some restrictions on the Venezuelan oil industry by allowing Chevron Corporation to resume certain transactions related to its joint ventures in Venezuela.[30]

In addition, OFAC has applied sanctions to several non-Venezuelan companies deemed to have operated in the Venezuelan oil sector and to have provided material assistance to sanctioned Venezuelan entities in the oil sector. This includes Mexico-based entities Libre Abordo and Schlager Business Group,[31] which were accused of assisting PdVSA through brokering crude oil exports, and Russia-based Evrofinance Mosnarbank, which was accused of financing PdVSA’s operations.[32]


US sanctions involving Nicaragua have been mostly limited to specific senior government leaders in connection with allegations of human rights abuses under the Daniel Ortega administration. The US imposed sanctions against four senior members of the Ortega administration between December 2017 and July 2018 under the Magnitsky Act, which authorises sanctions against those accused of human rights abuses around the world. As the government continued its crackdown on protests, in November 2018 President Trump issued Executive Order 13851, which provided an independent basis for sanctions relating to human rights abuses in Nicaragua specifically.

Additionally, the Nicaragua Human Rights and Anticorruption Act of 2018, passed in December 2018, imposed targeted sanctions on Nicaraguan officials designated as responsible for human rights violations and restricted lending to the Nicaraguan government by international financial institutions.[33] These provisions were further strengthened by the Reinforcing Nicaragua’s Adherence to Conditions for Electoral Reform Act of 2021, which: increased sanctions on key actors of the Ortega administration; expanded sanctions coordination with Canada, the European Union and nations in Latin America and the Caribbean; and required a formal review of whether Nicaragua should continue to be allowed to remain in the Central America Free Trade Agreement.[34]

OFAC has since designated several dozen high-ranking Nicaraguan officials and associates of President Ortega as SDNs under the order. Sanctions against Nicaragua are maintained at 31 CFR Part 582.

Subject matter-related US sanctions

Human rights

The US has imposed sanctions under the Magnitsky Act targeting those responsible for serious human rights abuses and corruption around the world. There have been several instances of OFAC designating individuals from Latin American countries. For example, in May 2019, OFAC designated Roberto Sandoval Castañeda, a Mexican national and former governor of the Mexican state of Nayarit, for his alleged role in accepting bribes from and having ties to Mexican drug cartels.[35] In 2021, OFAC used Magnitsky Act authorities to target a Guatemalan politician for corruption,[36] two senior El Salvadorean officials and a related family member with ties to international criminal gang MS-13,[37] and two affiliates of the governments of Guatemala and El Salvador for corruption.[38] More recently, Magnitsky authorities have been used against former and current Paraguayan officials.[39]

Narcotics trafficking

US sanctions related to foreign drug trafficking date to October 1995, when President Clinton signed Executive Order 12978 and created the Counter Narcotics Trafficking Sanctions programme, which targeted Colombian narcotics traffickers specifically. In 1999, President Clinton signed into law the Kingpin Act, which authorises sanctions against foreign narcotics traffickers regardless of country, and notably carries significantly higher penalties than the Counter Narcotics Trafficking Sanctions.[40] While the Counter Narcotics Trafficking Sanctions are limited to Colombian trafficking, the Kingpin Act has been used to target individuals in Ecuador,[41] Mexico,[42] the Dominican Republic[43] and Panama,[44] as well as Colombia.[45]

Lessons from select US enforcement action examples

Ensure wholly owned subsidiaries maintain compliance programmes

Potential violations of the CACR continue to represent the most significant sanctions-related risk arising out of commercial dealings in Latin America.

On 21 April 2022, OFAC announced a US$141,442 settlement with multinational mining conglomerate Newmont Corporation for violations of the CACR. In 2016, Newmont, through its subsidiary Newmont Suriname, entered into an agreement with a Suriname-based third-party distributor to supply explosives for use in a gold mining project in Suriname. The distributor contracted with a Cuban entity, Unión Latinoamericana de Explosivos, to source the explosives, with the importation of Cuban-origin explosives occurring on at least four occasions. Under the CACR, wholly owned subsidiaries of US corporations are subject to the same prohibitions as their US parent company. According to OFAC, a Newmont Suriname employee, who had not participated in export and trade sanctions training, did not understand the implications of US sanctions on Cuba when processing the transaction. Furthermore, Newmont Suriname’s purchase orders did not include standard sanctions-related representations and warranties, and the subsidiary did not require suppliers to provide country-of-origin information for goods. OFAC also concluded a US$45,908 settlement with Florida-based Chisu International Corporation, a small, individually managed, Florida-based explosives distributor. Based on OFAC’s settlement notice, it appears that Chisu oversaw Newmont’s Suriname explosives distributor.

As this enforcement action makes clear, Cuba sanctions can impact firms doing business outside of Latin America in unexpected ways. As such, wholly owned subsidiaries of US companies should be fully cognisant of their compliance responsibilities and ensure that employees of foreign subsidiaries receive adequate compliance training that emphasises the identification of red flags. Companies should also take steps to analyse suppliers’ and vendors’ compliance programmes to reduce the risk of importing potential sanctions liability from a third party’s own compliance failures.

Maintain compliance focus when exploring new areas of business

The ever-changing nature of US sanctions affecting various jurisdictions in Latin America can also provide both opportunities and risks that must be managed. When the Obama administration relaxed certain sanctions affecting Cuba in 2015, numerous companies took steps to take advantage of the relaxed rules. But there were risks in taking advantage of the relaxed rules, and on 3 January 2022, OFAC published a US$91,172.29 settlement with Airbnb Payments, Inc (Airbnb) for violations of the CACR.[46] According to OFAC, Airbnb facilitated payments related to non-approved categories of travel to Cuba and failed to keep required records of its customers’ Cuba travel related to transactions authorised under the Obama administration’s 2015 easing of travel-related restrictions. Under the relaxed travel rules, the CACR identified 12 categories of approved Cuba-related travel, including family visits, journalistic activity, support for the Cuban people and educational activities. Notably, pure tourist travel was not one of the identified categories. Travellers utilising the authorisations were required to adhere to the specific qualifying conditions for each approved category.

OFAC suggested that the violations resulted from Airbnb’s failure to effectively manage sanctions risks while rapidly scaling up its Cuba business following the 2015 regulatory changes. After conducting an internal review of its compliance programme, Airbnb discovered that it had facilitated thousands of transactions in violation of the CACR, including those related to individuals travelling for non-approved purposes. Airbnb also engaged in inadequate record-keeping related to traveller activities and facilitated Cuba-related transactions with non-US persons prior to receiving a specific licence.

The Airbnb enforcement action offers a number of lessons for companies entering new areas of business following regulatory changes. First and foremost, when establishing new operations in sanctioned jurisdictions, it is important that the centrality of sanctions compliance is emphasised across departments within the company. In Airbnb’s case, some of the record-keeping violations resulted from the continued operation of an older version of the Airbnb mobile application, which allowed customers to book travel to Cuba without the required attestation regarding the purpose of the travel. Robust compliance training for technology teams can help prevent technical defects inadvertently causing violations. Additionally, when potential violations are discovered, conducting a proactive internal investigation, prompt disclosure to OFAC and transparent cooperation are essential; the maximum statutory penalty in Airbnb’s case was over US$600 million, yet the company paid only US$91,172.29.

Consider sanctions risk throughout the region

While many practitioners may be familiar with sanctions programmes against Cuba, Venezuela or Nicaragua, they should note that limiting business activities in these countries alone would not eliminate sanctions risk. As noted above, Magnitsky Act, Kingpin Act and other authorities have been used to target individuals in Mexico, Guatemala, El Salvador, the Dominican Republic, Paraguay, Ecuador, Colombia and Panama. An effective compliance programme considers all potential risks of conducting business activities in the region.

Pay attention to changes in restrictions and enforcement

As noted above, different US administrations have taken varied approaches to sanctions and their enforcement. Aside from ideological differences and competing policy priorities, new administrations will face different environments with new facts and trade-offs. Practitioners should consider the potential future changes – both tightening and loosening – of sanctions programmes in the region.

As an example, on 27 May 2022, OFAC announced a US$255,937.86 settlement with Banco Popular de Puerto Rico (BPPR) for violations of the Venezuela Sanctions Regulations. According to OFAC, BPPR failed to adequately implement the new August 2019 sanctions against the government of Venezuela, resulting in the bank providing account services, including 337 transactions totalling US$852,126, to two low-level GoV employees. Transactions with these customers continued for a period of 14 months, despite BPPR recognising the need to implement Executive Order 13884 shortly after its issuance. The penalty demonstrates the importance of having sufficient know-your-customer policies and procedures in place to facilitate sanctions compliance reviews when new prohibitions come into effect.

Design an effective compliance programme

When advising corporate clients in Latin America, advisers should begin by considering the 2020 Framework for OFAC Compliance Commitments (the Framework). Under the Framework, entities that ‘conduct business in or with the US, US persons, or using US-origin goods or services’ are encouraged to ‘employ a risk-based approach’ to sanctions compliance. According to OFAC, there are five essential components of an effective OFAC compliance programme:

  • management commitment;
  • risk assessment;
  • internal controls;
  • testing and auditing; and
  • training.

Constructing an effective compliance programme is important not only for avoiding a potential enforcement action, but also for mitigating the severity of a potential response by OFAC in the event that violative conduct is discovered – a fact the Framework emphasises.

Compliance with US sanctions is the responsibility of any entity that touches on US jurisdiction. OFAC has previously penalised companies where the only US touchpoint was back-office functions performed on behalf of a foreign affiliate.[47] Latin American companies should understand exactly where there is jurisdictional nexus to the US, to ensure that any high-risk activity is avoided. This includes US employees.

Additionally, even with an effective compliance programme in place, human error can still result in compliance failures. For instance, on 23 December 2021, OFAC announced a US$9,766.39 settlement with TD Bank, NA (TDBNA) resulting from violations of the Foreign Narcotics Kingpin Sanctions Regulations. According to OFAC, over a period of four years, TDBNA processed 145 transactions totalling US$35,514.13 on behalf of an SDN customer. In February 2016, TDBNA opened two accounts for Esperanza Caridad Maradiaga Lopez, who was designated by OFAC in 2013. Despite TDBNA’s compliance programme issuing a sanctions screening alert due to last name and date of birth matches, TDBNA analysts improperly dismissed the alert. Analysts would dismiss an additional three alerts over the following four years, until a fifth alert resulted in closure of the account. Then, after the account was closed, TDBNA’s fraud unit accidentally credited and re-opened one of the accounts, apparently unaware of the sanctions issues. The settlement demonstrates that even in a relatively sophisticated institution with a robust compliance programme, human error and inadequate cross-departmental information sharing can result in compliance failures.

Consider sanctions risk in the context of mergers and acquisitions

Mergers and acquisitions represent one area in particular that presents heightened compliance challenges. First, when conducting pre-transaction due diligence, it is important to consider that an acquirer will be liable for any sanctions violations of the target that occurred within the statute of limitations. For example, in 2019, OFAC announced a US$66,212 settlement with Chubb Limited regarding CACR violations committed between 2010 and 2014 by ACE Limited.[48] These violations occurred before ACE and Chubb merged in 2016, but Chubb was nonetheless responsible for ACE’s earlier violations. In explaining the relatively small size of the settlement, OFAC noted Chubb’s substantial cooperation and voluntary self-disclosure of the violations.

Second, getting an accurate picture of the target’s existing sanctions compliance architecture will assist in identifying potential risks going forward. For instance, for a target with limited US exposure, sanctions compliance is not necessarily an important consideration. But once incorporated into a multinational corporation or one that does significant business with the US, the target’s use of Cuban contractors may present issues.

Latin American countries’ sanctions programmes

Most Latin American countries do not have a tradition of enacting, or specific domestic legal authorities by which they can enact, their own sanctions. For example, the largest economy in the region, Brazil, does not have independent authorities to impose unilateral sanctions, but has a law pursuant to which it will implement United Nations sanctions.[49] In addition, on some occasions, Latin American countries have relied on the legal authority of the Inter-American Treaty of Reciprocal Assistance (the Rio Treaty) to implement sanctions. Even so, this practice has been relatively rare compared to the sanctions programmes implemented by the US or the European Union.

The Rio Treaty was signed in 1947 as a collective security pact among 19 countries in the western hemisphere.[50] Beyond the mutual defence provisions, the Treaty authorises its signatory nations collectively to engage in ‘partial or complete interruption of economic relations’.[51]

This provision has been used to enact collective economic sanctions several times. Most recently, in September 2019, several Treaty members, including the US, Argentina, Brazil, Chile, Colombia, the Dominican Republic, El Salvador, Guatemala, Haiti, Honduras and Paraguay, supported a resolution convening consultations regarding the Venezuelan crisis.[52] After the consultations, the parties voted to investigate and sanction certain members of the Maduro regime.[53] The same provisions were used to enact since-repealed sanctions against the Dominican Republic in 1960 [54] and against Cuba in 1964.[55]

While sanctions under the Rio Treaty tend to be rare, they are nonetheless notable. Even Latin American countries with no independent domestic sanctions authority may rely on the Treaty to implement sanctions as a collective organisation. Practitioners should continue to monitor this area for developments.

Sanctions enactment by individual Latin American countries has been rarer still. For example, no Latin American country has implemented its own sanctions against Russian entities in response to Russia’s invasion of Ukraine, and only one country, Costa Rica, has instructed its businesses to comply with US sanctions directives against Russia.[56] The leaders of the two largest economies in the region, Brazil and Mexico, have both stated that their countries will not be implementing sanctions against Russian entities.[57] Mexico has also implemented its own blocking statute, through which persons within Mexico are prohibited from taking action affecting commerce or investment so as to comply with foreign laws, including sanctions.[58] In some instances, companies may need to weigh risks of compliance with US sanctions against the risks of Mexico’s blocking law. For example, in 2006, Starwood Hotels & Resorts Worldwide Inc was caught in a diplomatic dispute between the US and Mexico. US officials asked the Hotel Maria Isabel Sheraton in Mexico City to expel a group of Cuban officials meeting with US energy executives. To comply with US sanctions, the hotel complied with the request, but then faced complaints from Mexican government officials over its apparent violation of Mexico’s blocking law.[59] Companies should carefully consider the facts and circumstances of each situation when determining how to manage sanctions compliance risks.

Because it is relatively rare for Latin American countries to implement their own sanctions, the primary risk in navigating sanctions compliance in Latin America remains compliance with US sanctions programmes.


[1] Eric J Kadel, Jr is a partner and Jacob M Marco is an associate at Sullivan & Cromwell LLP. The authors would like to thank Samuel Cutler, previously an associate at the firm, for contributing to the chapter.

[2] Christopher Sabatini, Opinion, ‘America’s List of “Undemocratic and Corrupt Actors” Just Keeps Growing’, New York Times (5 October 2021),

[3] The US Department of State maintains certain other lists, such as the Section 515.582 list, which lists authorised imports into the US from independent Cuban entrepreneurs.

[4] 50 U.S.C. § 4301 et seq.

[5] Presidential Determination No. 2022-22 of 2 September 2022. See Continuation of the Exercise of Certain Authorities Under the Trading With the Enemy Act, 87 Fed. Reg. 54859 (8 September 2022),

[6] 22 U.S.C. § 2370.

[7] The Cuban Democracy Act is also known as the Torricelli Act.

[8] 22 U.S.C. § 6001 et seq.

[9] 22 U.S.C. § 6021 et seq. The Cuban Liberty and Democratic Solidarity Act is also known as the Helms-Burton Act.

[10] 22 U.S.C. § 7201 et seq. Specifically, the law barred the President from imposing unilateral agricultural or medical sanctions against a foreign country or entity, subject to certain conditions and exceptions. The law also contained several Cuba-specific provisions, such as clarifying that the law does not modify the prohibition on imports of any Cuban-origin goods and limiting travel to Cuba and financial transactions with Cuban entities for purposes authorised by the law.

[11] Press Release, White House, ‘President Barack Obama, Statement by the President on Cuba Policy Changes’ (17 December 2014),

[12] See, e.g., Adam Goldman, ‘U.S. spy freed by Cuba was longtime asset’, The Washington Post (18 December 2014),, and Dana Ford and Juan Carlos Lopez, ‘Cuba releases 53 political prisoners’, CNN (12 January 2015),

[13] Family travel and remittances were authorised in 2009. In 2011, the administration authorised educational travel, including people-to-people educational travel and non-family remittances. Restrictions on travel and remittances were further relaxed throughout 2015 and 2016. See Mark P Sullivan, ‘Cuba: U.S. Restrictions on Travel and Remittances’, Congressional Research Service (15 December 2022),

[14] Cuban Assets Control Regulations, 80 Fed. Reg. 2291 (16 January 2015),

[15] Press Release, White House, ‘Certification – Report to Congress with Respect to the Proposed Rescission of Cuba’s Designation as a State Sponsor of Terrorism’ (14 April 2015),

[16] Cuban Assets Control Regulations, 82 Fed. Reg. 51998 (9 November 2017),

[17] Secretary of State Michael R Pompeo’s Remarks, US Embassy in Chile (published 18 April 2019; remarks made 17 April 2019),

[18] ‘U.S. Announces Designation of Cuba as a State Sponsor of Terrorism’, US Embassy in Cuba (11 January 2021),

[19] Cuban Assets Control Regulations, 87 Fed. Reg. 35088 (9 June 2022),

[20] US Dep’t of State press statement, ‘Biden Administration Expands Support to the Cuban People’ (16 May 2022),

[21] Press Release, US Dep’t of Treasury, ‘Treasury Sanctions Cuban Police Force and Its Leaders in Response to Violence Against Peaceful Demonstrators’ (30 July 2021),

[22] Dave Sherwood, ‘Cuba, US Officials Meet in Havana to Discuss Anti-terrorism Measures’, Reuters (28 April 2023),

[23] Executive Order 13692, 80 Fed. Reg. 12747 (11 March 2015).

[24] Executive Order 13808, 82 Fed. Reg. 41155 (29 August 2017).

[25] Executive Order 13827, 83 Fed. Reg. 12469 (21 March 2018).

[26] Executive Order 13835, 83 Fed. Reg. 24001 (24 May 2018).

[27] Executive Order 13857, 84 Fed. Reg. 509 (30 January 2019).

[28] Executive Order 13884, 84 Fed. Reg. 38843 (7 August 2019).

[29] Executive Order 13850, 83 Fed. Reg. 55243 (2 November 2018). See also Press Release, US Dep’t of Treasury, ‘Treasury Sanctions Venezuela’s State-Owned Oil Company Petroleos de Venezuela, S.A.’ (28 January 2019),

[30] General License No. 41, Venezuela Sanctions Regulations, US Dep’t of Treas. (26 November 2022), See also General License No. 8K, Venezuela Sanctions Regulations (26 November 2022),

[31] Press Release, US Dep’t of Treasury, ‘Treasury Targets Sanctions Evasion Network Supporting Corrupt Venezuelan Actor’ (18 June 2020),

[32] Press Release, US Dep’t of Treasury, ‘Treasury Sanctions Russia-based Bank Attempting to Circumvent U.S. Sanctions on Venezuela’ (11 March 2019),

[33] Nicaragua Human Rights and Anticorruption Act of 2018, PL 115-335, 20 December 2018, 132 Stat 5019.

[34] Reinforcing Nicaragua’s Adherence to Conditions for Electoral Reform Act of 2021, PL 117-54, 10 November 2021, 135 Stat 413.

[35] Press Release, US Dep’t of Treasury, ‘Treasury Works with Government of Mexico Against Perpetrators of Corruption and their Networks’ (17 May 2019),

[36] Press Release, US Dep’t of Treasury, ‘Treasury Sanctions Current and Former Guatemalan Officials for Engaging in Corrupt Activities’ (26 April 2021),

[37] Press Release, US Dep’t of Treasury, ‘Treasury Targets Corruption Networks Linked to Transnational Organized Crime’ (8 December 2021),

[38] Press Release, US Dep’t of Treasury, ‘Treasury Issues Sanctions on International Anti-Corruption Day’ (9 December 2021),

[39] Press Release, US Dep’t of Treasury, ‘Treasury Sanctions Paraguay’s Former President and Current Vice President for Corruption’ (26 January 2023),

[40] Individuals who violate the Kingpin Act are subject to criminal penalties of up to 10 years’ imprisonment or fines, or both, under Title 18 of the US Code. Entities that violate the Kingpin Act are subject to criminal penalties of up to US$10 million. Their officers, directors and agents who knowingly participate in a violation are subject to criminal penalties of up to 30 years’ imprisonment or a US$5 million fine, or both. Individuals and entities are also subject to civil penalties of up to US$1.7 million. See 21 U.S.C. § 1906(a) and 31 C.F.R. § 598.701. The maximum civil penalty under the Counter Narcotics Trafficking Sanctions is US$356,579, or twice the value of the transaction, whichever is greater; criminal penalties are limited to those who wilfully violate these sanctions and may not exceed US$1 million and 20 years’ imprisonment. See 31 C.F.R. § 536.701.

[41] Press Release, US Dep’t of Treasury, ‘Treasury Sanctions Major Ecuadorian and Mexican Narcotics Traffickers With Ties to the Sinaloa Cartel and CJNG’ (10 February 2022),

[42] Press Release, US Dep’t of Treasury, ‘Treasury Identifies Sinaloa-based Mexican Narcotics Trafficker That Helps Fuel the US Opioid Epidemic’ (12 May 2021),

[43] Press Release, US Dep’t of Treasury, ‘Treasury Designates Dominican Republic-Based Peralta Drug Trafficking Organization Under the Kingpin Act’ (20 August 2019),

[44] Press Release, US Dep’t of Treasury, ‘Treasury Sanctions the Waked Money Laundering Organization’ (5 May 2016),

[45] Press Release, US Dep’t of Treasury, ‘Treasury Targets Colombians Linked to Oficina de Envigado Crime Boss Under Kingpin Act’ (14 February 2018),

[46] US Dep’t of the Treasury, ‘Enforcement release: January 3, 2022: OFAC Settles with Airbnb Payments, Inc. for $91,172.29 Related to Apparent Violations of the Cuban Assets Control Regulations’ (3 January 2022),

[47] US Dep’t of Treasury, ‘Enforcement Information for July 10, 2012: Great Western Malting Co. Settles Apparent Violations of Cuban Assets Control Regulations’ (10 July 2012),

[48] US Dep’t of Treasury, ‘Enforcement Information for December 9, 2019: Chubb Limited (as Successor Legal Entity of the Former ACE Limited) Settles Potential Liability for Apparent Violations of the Cuban Assets Control Regulations’ (9 December 2019),

[49] Law No. 13,810 (8 March 2019) (Brazil).

[50] Inter-American Treaty of Reciprocal Assistance (Rio Treaty), 2 September 1947, 62 Stat. 1681, 21 U.N.T.S. 77.

[51] id., Article 8.

[52] Press Release, Organization of American States (OAS), ‘States Parties to the [Inter-American Treaty of Reciprocal Assistance] in the Permanent Council Approve Establishment of Organ of Consultation and Convene Meeting of Foreign Ministers’ (11 September 2019),

[53] Press Release, OAS, ‘Resolution to the Thirtieth Meeting of Consultation of Ministers of Foreign Affairs, Acting as the Consultative Organ in Application of the Inter-American Treaty of Reciprocal Assistance (TIAR)’ (23 September 2019),

[54] ‘Sixth Meeting of Consultation of Ministers of Foreign Affairs’, OAS (16–21 August 1960),

[55] ‘Ninth Meeting of Consultation of Ministers of Foreign Affairs’, OAS (21–26 July 1964),

[56] Chase Harrison, ‘One Year in, What Does the Ukraine Conflict Mean for Latin America?’, Americas Society/Council of the Americas (9 February 2023),

[57] Anthony Esposito, Ana Isabel Martinez and Daina Beth Solomon, ‘Mexico declines to impose economic sanctions on Russia’, Reuters (2 March 2022), See also Jalen Small, ‘Mexico, Brazil Leaders Ignore Their UN Delegates, Refuse to Sanction Russia’, Newsweek (4 March 2022),

[58] Law for the Protection of Trade and Investment of Foreign Standards that Violate International Law, Mexico’s Official Daily of the Federation of 23 October 1996.

[59] ‘Cubans’ hotel ouster riles Mexico’, The Washington Times (8 February 2006),

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