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 because it operates in the Venezuelan oil sector. As a result, US Persons (i.e., entities organized under US laws and their non-US branches; individuals and entities physically located in the United States; and US citizens and permanent resident aliens (“Green Card” holders) wherever located or employed) are prohibited, in the absence of an OFAC license, from transacting, directly or indirectly, with PdVSA and any entities owned 50% or more by PdVSA (“PdVSA Subs”). In addition, except as permitted under OFAC licenses, US Persons are required to block property or property interests of PdVSA/PdVSA Subs that are currently in the United States, come within the United States or the possession or control of any US Person.
On May 21, 2018, the President signed a new Executive Order (the “Order”) related to Venezuela entitled “Prohibiting Certain Additional Transactions with Respect to Venezuela.” According to a statement from the White House, this action is intended to “prevent the Maduro regime from … liquidating Venezuela’s critical assets.” These new US financial sanctions were imposed after Venezuela held elections this past weekend that were described as “fraudulent” in a press statement from the US State Department. Please see our prior blog posts concerning the previous Venezuela-related Executive Orders: (i) Executive Order 13827 of March 19, 2018 here, (ii) Executive Order 13808 of August 24, 2017 here, and (iii) Executive Order 13692 of March 8, 2015 here.
On March 19, 2018, the President issued a new Executive Order related to Venezuela entitled “Taking Additional Steps to Address the Situation in Venezuela” (“Venezuela EO”) available here. The Venezuela EO is the first Executive Order that specifically targets the use of cryptocurrency. Please see our prior blog posts concerning the previous Venezuela-related Executive Orders: (i) Executive Order 13808 of August 24, 2017 here and (ii) Executive Order 13692 of March 8, 2015 here.
On August 24, 2017, President Trump signed an Executive Order (“Order”) imposing additional sanctions on Venezuela. The Order states that these sanctions, which primarily target the Government of Venezuela and the Venezuelan oil industry, are in response to the deepening political and humanitarian crisis in Venezuela. The Order adds to a growing list of restrictions that apply to Venezuela, which is already subject to an arms embargo and licensing requirements on exports and reexports of specific categories of goods, software, and technology to military end-users or for military end-uses in Venezuela. The Order also follows the designation as Specially Designated Nationals of various Venezuelan government officials (including President Nicolas Maduro) pursuant to Executive Order 13692 of March 8, 2015 (see prior blog post here regarding this order).