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Venezuela

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On October 21, 2019, the US Commerce Department’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to further restrict exports and reexports of items to Cuba (“the Amendment“). According to BIS, the Amendment was made to further restrict the Cuban government’s access to items subject to the EAR, thereby supporting the US government’s national security and foreign policy decision to hold the Cuban regime accountable for its repression of the Cuban people…

October 30, 2019 by Nicholas F. Coward, Alexandre (Alex) Lamy and Meghan Hamilton On October 17, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued and amended as General License No. 13D (“GL 13D”) to continue the validity period for transactions concerning Nynas AB and its affiliates (“Nynas”), as further described below. In addition, on October 21, 2019, OFAC re-issued as General License No. 8D (“GL 8D”) to continue the validity period certain maintenance activities involving Petróleos de Venezuela S.A. (“PdVSA”)…

On September 30, 2019, the 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. GL 3G was amended to extend the validity period of the authorization for transactions and activities that are ordinarily incident and necessary…

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…

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 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.)