Assuming arguendo that this information is also known to some of the suspect financial institutions, corrupt PEPs, and individuals most likely to be named, compliance officers should alert their staff to maintain a high level of vigilance for large funds transfers being requested for transfer outside the US, and into offshore financial centres, whether located in the Caribbean, or in Western Europe.

US Regulators may take a dim view of the fact that a freeze order was served upon your bank, only to learn that you approved the transfer, hours earlier, of the money, into a known tax haven jurisdiction. It might make the agency involved decide to take a hard look at your compliance policies and procedures, including a "look-back" of a couple of years. Since your institution may not have properly vetted the Source of Funds for the since-departed cash, you might have a problem.

Ensure that any large funds transfer request that seems to be outside the normal course of business, and involving known Venezuelan nationals, or companies in which they have an interest, gets a good look.