The US Financial Crimes Enforcement Network has issued an 'advisory' to alert financial institutions about the methods that senior Venezuelan political figures and their associates might be using to move and hide proceeds of corruption.

The so-called 'advisory' (actually a note that is not legally binding) contains some financial 'red flags' that, the agency believes, might indicate that corruption has taken place.

FinCEN is warning of the misuse of Venezuela’s government-sponsored food distribution programme, which is known as Los Comités Locales de Abastecimiento y Producción (“Local Supply and Production Committees”) and is also referred to as the “CLAP program.” CLAP was created in 2016 for the purpose of providing subsidised food rations to Venezuelans and the Americans believe that the Venezuelan Government is using it to "enrich corrupt regime insiders."

The Maduro regime also has experimented with the use of digital currency to circumvent sanctions and generate revenue. It has developed a digital currency called the “petro” and reportedly continues to develop new tokens. The US Government has banned US banks from handling these.

In 2018, the Russian bank Evrofinance Mosnarbank emerged as the international financial institution that was most willing to finance the petro. In March this year, the US Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Evrofinance Mosnarbank for supporting Petroleos de Venezuela (PdVSA), the state-owned oil company against which the Trump administration levied sanctions in January. All HNW employees at PdVSA are counted as 'foreign officials' in accordance with the US Foreign Corrupt Practices Act 1977.