On September 9, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a new Venezuela-related general license (General License 34) to authorize transactions involving certain Government of Venezuela-related individuals that would otherwise be prohibited by Executive Order (“EO”) 13884. EO 13884 blocks all property of the Government of Venezuela. The “Government of Venezuela” is defined broadly in EO 13884 to include any person who has acted or purported to act directly or indirectly…

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”). 

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 March 14, 2019, OFAC reissued General License 7 (“GL 7”) as General License 7A (“GL 7A”) to extend the general license’s authorization for certain activities involving PDV Holding, Inc. (“PDVH”) and CITGO Holding, Inc. (“CITGO”).

On March 7, 2019, the Federal Register published Presidential Notice of March 5, 2019 Continuation of the National Emergency With Respect to Venezuela, which extends for an additional year the national emergency first declared by Executive Order (EO) 13692 (March 8, 2015) based on the Government of Venezuela’s erosion of human rights guarantees; persecution of political opponents; curtailment of press freedoms;

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.)

On January 31, 2019, OFAC issued eleven new FAQs and amended two existing FAQs in connection with the designation of Petróleos de Venezuela, S.A. (“PdVSA”) as a Specially Designated National (“SDN”) pursuant to Executive Order 13850 on January 28, 2019. In addition, on February 1, 2019, OFAC amended two PdVSA-related general licenses (“GL”) and issued two additional FAQs describing the scope of those amendments, which modify the terms under which certain transactions involving PdVSA bonds and securities are authorized. Our prior blog post on the SDN designation of PdVSA and the previously issued Venezuela GLs is available here.

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 July 19, 2018, the Office of Foreign Assets Control (OFAC) issued Venezuela General License 5. General License 5 authorizes US persons to engage in all transactions related to, the provision of financing for, and other dealings in the Petroleos de Venezuela SA 2020 8.5 Percent Bond that would be prohibited by Subsection 1(a)(iii) of  Executive Order (EO) 13835 of May 21, 2018 (“Prohibiting Certain Additional Transactions With Respect to Venezuela”). OFAC also published two new Frequently Asked Questions (FAQs). One explains why…