On November 5, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a new Venezuela-related general license (General License No. 35) (“GL 35”) to authorize certain administrative transactions with the Government of Venezuela (“GOV”) prohibited by Executive Order (“EO”) 13884 (“Blocking Property of the Government of Venezuela”); issued General License No. 34A (“GL 34A”), which supersedes and replaces General License No. 34, and authorizes transactions involving certain GOV-related individuals prohibited by EO 13884; and identified five current GOV officials on the Specially Designated Nationals and Blocked Persons List (“SDN List”) pursuant to EO 13884.
Then, on November 21, 2019, OFAC announced the amendment of the Venezuela Sanctions Regulations (“VSR,” 31 C.F.R. Part 591) to incorporate additional EOs; make certain clarifying changes; add a GL authorizing US Government activities; and add an interpretive provision regarding activities related to judicial processes. The VSR regulatory amendments took effect on November 22, 2019 concurrent with their publication in the Federal Register, available here.
These Venezuela sanctions developments are described in more detail below. Our previous blog posts about US sanctions targeting Venezuela are available here.
On September 30, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended two Venezuela-related general licenses (“GLs”), re-issued as General License 3G (“GL 3G”) and General License 9F (“GL 9F”), to extend the authorization for dealings in certain bonds and other securities, as further outlined below. Our blog post regarding previous amendments to these GLs is available here.
On June 26, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended Venezuela-related General License 13A (re-issued as General License 13B) to extend its expiration date from July 27, 2019 to October 25, 2019. General License 13B continues to authorize transactions with Nynas AB, which is owned more than 50% by Petróleos de Venezuela SA (“PdVSA”), and any of Nynas AB’s subsidiaries. PdVSA was designated 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. Dealings with entities owned 50% or more by PdVSA are prohibited absent OFAC authorization (i.e., a general or specific license). Our previous blog post regarding the application of US sanctions to certain PdVSA subsidiaries is available here.
In addition, OFAC extended the expiration dates of two general licenses related to GAZ Group (“GAZ”), which was designated as an SDN on April 6, 2018 for being owned or controlled by Oleg Deripaska. Please see our blog post regarding this designation here.