On June 6, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended three Venezuela-related general licenses (re-issued as General License No. 7B, General License No. 8A, and General License 13A) to clarify that these authorizations do not authorize US Persons to engage in transactions or dealings related to the exportation or reexportation of diluents, directly or indirectly, to Venezuela. Such general licenses (“GLs”) were originally issued concurrent with the designation of Petróleos de Venezuela SA (“PdVSA”) as a Specially Designated National (“SDN”) on January 28, 2019, under Executive Order 13850. Our original blog post regarding the designation of PdVSA is available here.
On April 17, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) continued its escalation of sanctions against Venezuela and Nicaragua through the designation of additional parties as Specially Designated Nationals (“SDNs”). OFAC issued two Venezuelan general licenses (“GLs”), amended certain Venezuelan GLs, and issued one FAQ, as further described below. A summary of OFAC’s measures is available here, and a related press release issued by the White House is available here.
The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) continues to escalate the use of sanctions against the Maduro regime as well as entities that support the Maduro regime through the designation of high-profile parties as Specially Designated Nationals (“SDNs”). These designations increase the compliance risks for both US and non-US parties attempting to do business with Venezuela. Companies should watch out for additional designations under the Venezuelan sanctions, including possible designations of companies in the financial sector, gold sector, or other key sectors of the Venezuelan economy.
On January 28, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated Petróleos de Venezuela, S.A. (“PdVSA”) as a Specially Designated National (“SDN”) under Executive Order 13850 of November 1, 2018. As a result, US Persons are prohibited from dealing with PdVSA as of January 28, unless authorized by OFAC. (For these purposes, US Persons are entities organized under US laws and their non-US branches; individuals and entities physically located in the United States; US citizens and permanent resident aliens (“Green Card” holders) wherever located or employed.)