Arrested for Allegedly Conspiring to Violate Venezuela-Related Sanctions through Complex Global Arrangements

Taskin Torlak, 37, of Turkey, was arrested in Miami, Florida, on November 2, 2024, for allegedly conspiring to violate U.S. sanctions as part of a scheme to transport oil from Venezuela for the benefit of Petróleos de Venezuela, S.A. (“PdVSA”), Venezuela’s state-owned oil and natural gas company.

Torlak was arrested as he attempted to depart the United States to return to Turkey.

Torlak is charged by complaint with one count of conspiring to violate the International Emergency Economic Powers Act (“IEEPA”).

According to the complaint, Torlak conspired with others to cause U.S. financial institutions to process transactions connected to the transport of Venezuelan oil for the benefit of PdVSA, which the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated as a Specially Designated National (“SDN”) in January 2019.

According to the complaint, beginning at least in or around November 2020, Torlak and others devised and implemented a complex scheme to violate and evade U.S. sanctions related to petroleum products from Venezuela and Iran. 

The scheme included obfuscating the identities of tankers moving the oil by re-naming and re-flagging vessels, covering vessel names with paint or blankets, and turning off the electronics that track vessels’ locations for the safety of ships and their crews.

Torlak and his co-conspirators allegedly received tens of millions of dollars from PdVSA in payment for transporting Venezuelan oil. They hid the ultimate beneficiaries of the related transactions from U.S. financial institutions, who then unwittingly processed payments in furtherance of the scheme.

The complaint further alleges that Torlak and his co-conspirators explicitly discussed the need to hide their conduct from the U.S. Government, its agencies, including OFAC, and commercial maritime entities.

The complaint Affidavit

• https://www.justice.gov/usao-dc/media/1376021/dl
• https://www.justice.gov/usao-dc/media/1376026/dl

From the above affidavits, here is a breakdown of red flags

MARITIME DECEPTION TECHNIQUES:

1. AIS/LRIT Manipulation:

- Coordinated shutdown of both tracking systems

- Timing: Systems disabled in the West Africa area, ~40 days "dark period."

- Physical disconnection of power cords and antenna connections

- Careful selection of flag jurisdictions that wouldn't question tracking gaps

VESSEL IDENTITY OBFUSCATION:

- Periodic vessel renaming (e.g., Sino Macro → Melissa Amy → Lisa)

- Strategic re-flagging to jurisdictions with minimal oversight

- Physical concealment using:

• Magnetic blankets
• Sale cloth covers
• Paint over vessel names/IMO numbers

- Use of separate "clean fleet" for legitimate transactions

DOCUMENTATION MANIPULATION:

- Changed Bills of Lading post-departure

- Modified product origin documentation (Venezuela → West Africa/Malaysia)

- Hard copy-only communication with terminals to prevent digital traces

- Careful structuring of charter party agreements

FINANCIAL LAYERING:

- Complex payment structures:

• Initial USD 3M deposits
• 40% upon vessel sailing
• 60% before breaking bulk

- Use of multiple jurisdictions:

• Singapore for petrochemical transactions
• Marshall Islands for registrations
• Indonesia for shipping services

- Structured small payments ($1,400-$30,791) through different U.S. banks

- Mixed currency invoicing (USD/EUR) to obscure patterns

INSURANCE SCHEMES:

- Avoided International Group P&I clubs

- Used Russian/Chinese insurers to evade scrutiny

- Structured reinsurance premiums through Vietnamese brokers

SCALE OF OPERATIONS:

- Confirmed payments: $32.8M

- Outstanding amounts: ~$25M

- Total scheme value: $57.8M

FLAG JURISDICTIONS HIERARCHY:

1. Preferred "No Questions" Flags:

- Djibouti (primary choice for "eyes closed" operations)

- Sierra Leone

- Mongolia

- Togo (noted as "black flag" but used)

2. Avoided Flags:

- Hong Kong (strict LRIT requirements)

- Any "government-based" flags with oversight

FINANCIAL FLOW JURISDICTIONS:

Each jurisdiction played a specific role:

1. "Clean" jurisdictions (Germany/Singapore) - initial payments
2. "Transit" jurisdictions (Marshall Islands/Indonesia) - intermediary services
3. "End" jurisdictions (Russia/Venezuela) - final beneficiaries

SOURCES

• https://www.justice.gov/usao-dc/pr/turkish-national-arrested-allegedly-conspiring-violate-venezuela-related-sanctions#:~:text=Torlak%20was%20arrested%20as%20he%20attempted%20to%20depart,violate%20the%20International%20Emergency%20Economic%20Powers%20Act%20%28%E2%80%9CIEEPA%E2%80%9D%29.
• https://www.turkishminute.com/2024/11/05/turkish-man-accused-of-violating-us-sanctions-on-venezuelan-oi/
• https://www.linkedin.com/feed/update/urn:li:activity:7259885601099812865?utm_source=share&utm_medium=member_desktop