On 13 February, the Office of Foreign Assets Control (OFAC) published the names of two individuals and 13 entities designated for blocking sanction under the Kingpin Act for involvement in narcotics trafficking. These included Venezuelan Vice President Tareck Zaidan El Aissami Maddah, and his business partner Samark Jose Lopez Bello, and a network of US and non-US business entities believed to be involved in their illicit activities. US persons are prohibited from virtually all dealings with blocked persons or their property. As clarified by a new OFAC Frequently Asked Question (FAQ), the designations do not generally prohibit dealings with the Government of Venezuela. But, it goes on to warn that “persons should be cautious in dealings with the government to ensure that they are not engaged in transactions or dealings, directly or indirectly, with an SDN, for example by entering into contracts that are signed by an SDN, entering into negotiations with an SDN, or by processing transactions, directly or indirectly, on behalf of the SDN, absent authorization or an applicable exemption.”