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1/19/2021

Treasury Targets Venezuelan Oil Sector Sanctions Evasion Network | U.S. Department of the Treasury

Treasury Targets Venezuelan Oil Sector Sanctions Evasion
Network
January 19, 2021

Washington – Today, the U.S. Department of the Treasury’s O ice of Foreign Assets Control
(OFAC) designated three individuals, fourteen entities, and six vessels for their ties to a
network attempting to evade United States sanctions on Venezuela’s oil sector. The
illegitimate Maduro regime has continued to use Petroleos de Venezuela, S.A. (PdVSA) as its
primary conduit for corruption to exploit and profit from Venezuela’s natural resources.
Today’s action, taken pursuant to Executive Order 13850, as amended, builds on OFAC’s June
18, 2020 designations targeting Libre Abordo, S.A. de C.V. (Libre Abordo) and a wider Mexicobased network involved in the illicit sale of Venezuelan oil. Today’s action targets additional
orchestrators and facilitators with ties to the Mexico network who have conspired with
Maduro’s oil minister, Tareck El Aissami Maddah (El Aissami), and indicted money launderer
Alex Nain Saab Moran (Saab) to broker the sale of hundreds of millions of dollars of
Venezuelan oil.
“Those facilitating the illegitimate Maduro regime’s attempts to circumvent United States
sanctions contribute to the corruption that consumes Venezuela,” said Secretary Steven T.
Mnuchin. “The United States remains committed to targeting those enabling the Maduro
regime’s abuse of Venezuela’s natural resources.”
The principal actors designated today include Alessandro Bazzoni (Bazzoni), Francisco Javier
D’Agostino Casado (D’Agostino), Philipp Paul Vartan Apikian (Apikian), Elemento Ltd
(Elemento), and Swissoil Trading SA (Swissoil).

CONTINUATION OF SANCTIONS EVASION NETW ORK
On June 18, 2020, OFAC designated Joaquin Leal Jimenez (Leal), Olga Maria Zepeda Esparza
(Zepeda), Veronica Esparza Garcia (Esparza), Libre Abordo, and Schlager Business Group S.
de R.L. de C.V. (Schlager Business Group) for operating a sanctions-evasion scheme
benefitting the illegitimate Maduro regime and PdVSA. The illegitimate Maduro regime,
PdVSA, and Saab enlisted Libre Abordo and Leal in a scheme designed to evade U.S.
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Treasury Targets Venezuelan Oil Sector Sanctions Evasion Network | U.S. Department of the Treasury

sanctions in which Leal served as the conduit between the Mexico-based network and Saab,
D’Agostino, and Bazzoni.
Elemento is based in Valletta, Malta, and has operated in the global oil sector since at least
2017. Elemento has purchased oil from PdVSA and then resold it to third-party customers on
behalf of Bazzoni. Between July 2019 and July 2020, Elemento li ed and brokered the sale
of at least five shipments of Venezuelan-origin crude oil supplied by PdVSA, several of which
were coordinated directly with Libre Abordo or Swissoil. Elemento was designated today for
operating in the oil sector of the Venezuelan economy and because it has materially
assisted, sponsored, or provided financial, material, or technological support for, or goods or
services to or in support of, PdVSA.
Swissoil, based in Geneva, Switzerland, participated in the scheme by assisting in the sale
and shipping of Venezuelan-origin crude oil to buyers in Asia. Swissoil o en acted as the
consignee, or the entity financially responsible for the receipt of a shipment, for oil
shipments brokered by Elemento. Swissoil was also the recipient of at least one shipment of
Venezuelan oil in Asia. Swissoil was designated today for operating in the oil sector of the
Venezuelan economy and because it has materially assisted, sponsored, or provided
financial, material, or technological support for, or goods or services to or in support of,
PdVSA.
D’Agostino, a dual Spanish-Venezuelan citizen, worked with Saab, Leal, and Bazzoni to
coordinate the purchase and sale of Venezuelan-origin crude oil on behalf of PdVSA.
D’Agostino has been involved in the Venezuelan oil sector since at least 2012 and has
partnered with Bazzoni and others on multiple business ventures with PdVSA. D’Agostino
has been implicated in a number of projects in the Venezuelan oil sector. D’Agostino was
designated today for operating in the oil sector of the Venezuelan economy and because he
has materially assisted, sponsored, or provided financial, material, or technological support
for, or goods or services to or in support of, PdVSA.
Bazzoni, along with D’Agostino, is a core facilitator of the network, connecting Elemento and
Swissoil with PdVSA and Saab. Bazzoni, an Italian citizen, has been instrumental in
coordinating the purchase and sale of Venezuelan-origin crude oil from PdVSA. Following
Saab’s June 2020 arrest in Cape Verde and OFAC’s designation of Leal, Bazzoni took over the
core coordinating role in the ongoing scheme to broker the re-sale of Venezuelan-origin
crude oil from PdVSA and charter vessels willing to go to Venezuela to load oil. Bazzoni was
designated today for operating in the oil sector of the Venezuelan economy and because he
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Treasury Targets Venezuelan Oil Sector Sanctions Evasion Network | U.S. Department of the Treasury

has materially assisted, sponsored, or provided financial, material, or technological support
for, or goods or services to or in support of, PdVSA.
Apikian, a Swiss national, is the owner and director of Swissoil, and has been involved in the
sale and shipment of Venezuela-origin crude oil. Apikian was designated today for having
acted or purported to act for or on behalf of, directly or indirectly, Swissoil.

ENTITIES DESIGNATED F OR B EING OW NED OR
CONTROLLED B Y B LOCKED PERSONS
Also designated today are nine entities owned or controlled by Bazzoni, D’Agostino, or
Elemento:
Elemento Oil and Gas Ltd (Elemento Oil) is a Malta-based entity incorporated in March
2015. Bazzoni is the sole shareholder of Elemento Oil. Elemento Oil was designated for
being owned or controlled by Bazzoni.
Elemento Solutions Limited is an entity incorporated in the United Kingdom. Elemento
Solutions Limited was designated for being owned or controlled by Elemento.
Element Capital Advisors Ltd is a Panama-based entity incorporated in the British Virgin
Islands and was designated for being owned or controlled by D’Agostino.
AMG S.A.S. di Alessandro Bazzoni & C. (AMG) is an entity incorporated in Italy. AMG was
designated for being owned or controlled by Bazzoni.
Serigraphiclab di Bazzoni Alessandro (Serigraphiclab) is an Italian entity incorporated as
a sole proprietorship owned by Alessandro Bazzoni. Serigraphiclab was designated for
being owned or controlled by Bazzoni.
Jambanyani Safaris is a Zimbabwe-based entity and was designated for being owned or
controlled by D’Agostino.
D’Agostino & Company, Ltd is an entity located in Venezuela. D’Agostino & Company, Ltd
was designated for being owned or controlled by D’Agostino.
Catalina Holdings Corp. (Catalina) is an entity incorporated in New York and was
designated for being owned or controlled by D’Agostino.
82 Elm Realty LLC (82 Elm) is a New York limited liability company and was designated
for being owned or controlled by D’Agostino.

VESSELS
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Treasury Targets Venezuelan Oil Sector Sanctions Evasion Network | U.S. Department of the Treasury

Today’s action also includes the designation and blocking of the following maritime entities
and vessels. The entities were designated for operating in the oil sector of the Venezuelan
economy, and the vessels were identified as blocked property of these entities. All the
vessels have recently li ed Venezuelan oil and thus have facilitated continued sanctions
evasion and related activities for PdVSA and the illegitimate regime of Nicolas Maduro:
Fides Ship Management LLC is located in Odessa, Ukraine and manages or operates
the following vessels:

Baliar is a Liberian-flagged crude oil tanker (IMO: 9192258).
Balita is a Cameroon-flagged crude oil tanker (IMO: 9176773).
Domani is a Cameroon-flagged shuttle tanker (IMO: 9041057).
Freedom is a Cameroon-flagged crude oil tanker (IMO: 9018464).
Instituto Nacional de los Espacios Acuaticos e Insulares (INEA) is located in Venezuela.
INEA is the registered owner of the vessel Maksim Gorky.

Maksim Gorky is a Russian-flagged crude oil tanker (IMO: 9590008).
Rustanker LLC is located in Krasnodarskiy Kray, Russia and is the registered owner of
the vessel Sierra.

Sierra is a Russian-flagged crude oil tanker (IMO: 9147447).

SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of these individuals and
entities that are in the United States or in the possession or control of U.S. persons are
blocked and must be reported to OFAC. In addition, any entities that are owned, directly or
indirectly, 50 percent or more by the designated individuals and entities, are also blocked.
OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or transiting) the
United States that involve any property or interests in property of blocked or designated
persons.
View identifying information on today’s action.
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