George Clemente Semerene Quintero, Sanctions Evasion, Miami FL, 2024

The Justice Department yesterday announced the unsealing of an indictment charging 10 defendants with conspiring to violate the International Economic Emergency Powers Act (IEEPA) for their roles in a scheme to evade US sanctions imposed on Petróleos de Venezuela, S.A. (PDVSA), the Venezuelan state-owned oil company, in January 2019.

According to the indictment, between January 2019 and December 2021, after learning of the sanctions imposed on PDVSA, the defendants devised a scheme to illegally procure aircraft parts, including Honeywell Turbofan Engines, from the United States to service PDVSA’s aircraft fleet in Venezuela, in violation of US sanctions and export controls.

The defendants allegedly concealed from US companies that the goods were destined for Venezuela and PDVSA by exporting them to third parties in other countries, including Novax Group SA (Novax), a Costa Rican company, and Aerofalcon SL (Aerofalcon), a Spanish company. The Department of Commerce added Novax and Aerofalcon to its Entity List in November 2023.

The defendants include:

Four individuals associated with PDVSA: Gilberto Ramon Araujo Prieto, 54, a PDVSA air transport manager and colonel in the Venezuelan military; Guillermo Ysrael Marval Rivero, 62, and Fernando Jose Blequett Landaeta, 52, both PDVSA air transport managers and logistics analysts responsible for procurement; and Semerene, PDVSA’s head of logistics, procurement and warehousing.

Four individuals associated with Novax: Luis Alberto Duque Carvajal, 63, of San Jose, Costa Rica, the owner of Novax; Melvin Aleman Espinoza, 39, Novax’s director of operations; Mikhail Largin, 60, Novax’s director of special projects; and Pedro Elias Sucre Salazar, 58, a Novax employee located in Venezuela.

Two individuals associated with Aerofalcon: Juan Carlos Gonzalez Perez, 60, the owner of Aerofalcon; and Juan David Guerra Viera, 54, a director for Aerofalcon.

The defendants are charged with conspiring to violate IEEPA, and if convicted, face a maximum penalty of 20 years in prison. Defendants Duque, Aleman, Sucre, Gonzalez, and Guerra Viera are additionally charged with submitting false or misleading export information and smuggling of goods, which respectively carry maximum penalties of five and 10 years in prison.

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