Treasury Targets Family Members and Associates of Maduro Regime

The Office of Foreign Assets Control (OFAC) is a bureau of the U.S. Department of the Treasury that administers and enforces U.S. economic and trade sanctions. It does this under legal authorities that Congress has given the President (mainly the International Emergency Economic Powers Act and the National Emergencies Act) and that are implemented through executive orders and Treasury regulations. For Venezuela, OFAC’s authority comes from those statutes plus Venezuela‑related executive orders (such as E.O. 13692 and 13850), which delegate to Treasury the power to block property and prohibit transactions with designated persons and sectors.

Executive Order (E.O.) 13850, signed in November 2018, is titled “Blocking Property of Additional Persons Contributing to the Situation in Venezuela.” It authorizes Treasury to block the property of persons who:

• operate in specified sectors of the Venezuelan economy (initially the gold sector, later extended to oil, financial, defense, etc.), and/or
• are responsible for or complicit in deceptive or corrupt transactions with the Government of Venezuela or its projects, including their immediate adult family members, and those who materially assist them.

E.O. 13692, signed in March 2015, earlier declared a national emergency regarding Venezuela and targets individuals—such as officials and others—who undermine democratic processes, commit serious human‑rights abuses, restrict free expression or assembly, or engage in significant public corruption. It also authorizes travel bans on such persons.

So, 13692 is the foundational order focused on human‑rights and democracy‑related misconduct by Venezuelan officials and others, while 13850 is a later, more sector‑ and corruption‑focused tool that also allows sanctioning immediate adult family members and those operating in key parts of Venezuela’s economy.

The Specially Designated Nationals and Blocked Persons (SDN) List is OFAC’s main public sanctions list. It names individuals and entities that are owned or controlled by, or acting for or on behalf of, targeted countries, as well as terrorists, narcotics traffickers, and others designated under various sanctions programs.

Being on the SDN List means that:

• All of the person’s property and interests in property that are in the United States or in the possession or control of U.S. persons are “blocked” (frozen), and
• U.S. persons are generally prohibited from engaging in any transactions or dealings with them unless authorized by OFAC.

In addition, entities that are 50% or more owned (directly or indirectly) by one or more SDNs are treated as blocked even if not separately named.

According to OFAC:

• Carlos Erik Malpica Flores is a nephew of Venezuelan First Lady Cilia Flores, a former national treasurer of Venezuela, and a former vice president of the state‑owned oil company Petróleos de Venezuela S.A. (PDVSA). He was first sanctioned in 2017 and re‑designated in December 2025 under E.O. 13692 for being a current or former official of the Government of Venezuela. Treasury states that he has been repeatedly linked to corruption at PDVSA and to a broader “familial web of corruption, nepotism, and narco‑trafficking.”

• Ramon Carretero Napolitano is a Panamanian businessman. OFAC says he has engaged in lucrative contracts with Nicolás Maduro’s regime, partnered in businesses with the Maduro‑Flores family, and facilitated shipments of Venezuelan petroleum products on behalf of the government. He was designated under E.O. 13850 for operating in the oil sector of the Venezuelan economy.

The newly designated family members are:

• Relatives of Carlos Erik Malpica Flores (under E.O. 13850):

  • Eloisa Flores de Malpica – his mother and sister of Cilia Flores.
  • Carlos Evelio Malpica Torrealba – his father.
  • Iriamni Malpica Flores – his sister.
  • Damaris del Carmen Hurtado Perez – his wife.
  • Erica Patricia Malpica Hurtado – his adult daughter.

• Relatives of Ramon Carretero Napolitano (under E.O. 13850):

  • Roberto Carretero Napolitano.
  • Vicente Luis Carretero Napolitano.

OFAC uses E.O. 13850 to target “immediate adult family members” of a person responsible for, or complicit in, deceptive or corrupt transactions with the Government of Venezuela. Treasury’s rationale is that these close relatives form part of familial financial networks that move or hide the proceeds of corruption and help sustain Maduro’s regime, so blocking them is intended to disrupt those networks.

For these designations:

• U.S. persons (U.S. citizens and residents, U.S. companies, and anyone in the United States) must:

  • Block (freeze) all property and interests in property of the designated persons that are in the U.S. or in their possession or control, and report those holdings to OFAC.
  • Refrain from any transactions or dealings with the designated persons (e.g., payments, provision of goods or services) unless a general or specific OFAC license applies.
  • Comply even if they did not know a transaction was prohibited; OFAC can impose civil penalties on a strict‑liability basis.

• U.S. and non‑U.S. financial institutions that process transactions involving the designees must block such funds if they transit the U.S. financial system and risk civil or criminal penalties if they facilitate prohibited dealings. OFAC warns that “financial institutions and other persons may risk exposure to sanctions” for certain transactions involving blocked persons.

• Foreign banks are not automatically barred from all activity but face significant risk: U.S. dollar payments or transactions clearing through U.S. banks that involve SDNs will be blocked, and OFAC can, in some programs, sanction foreign institutions that knowingly conduct significant transactions for blocked persons.

A designated person can seek removal (“delisting”) by filing a petition for administrative reconsideration with OFAC:

• Under 31 C.F.R. § 501.807, a sanctioned person (or a person owning a majority interest in blocked property) may submit a written petition—by email to OFAC.Reconsideration@treasury.gov—presenting arguments and evidence that:
  • there is insufficient basis for the designation, or
  • the circumstances that led to the designation have changed, and/or
  • proposed remedial steps (e.g., corporate reorganization, resignations, divestment) would negate the basis for sanctions.
• OFAC reviews the submission, may request additional information, and may—but is not required to—hold a meeting with the petitioner.
• After its review, OFAC issues a written decision granting or denying removal. There is no fixed statutory timeline; the length of the process varies case by case and can take many months or longer.

The December 19, 2025 Treasury release points designated persons to OFAC’s “Filing a Petition for Removal from an OFAC List” guidance, which incorporates these procedures.