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Web Alert: United States imposes further sanctions against Venezuela

23 May 2018

This Web Alert provides the club's members with a brief update on most recent United States (US) sanctions imposed against Venezuela:

President Trump issues new Executive Order

On 21 May 2018, President Trump issued an Executive Order imposing further economic sanctions by  US against Venezuela.

The Executive Order prohibits all transactions related to:

(i) the purchase of any debt owed to the Government of Venezuela, including accounts receivable;

(ii) any debt owed to the Government of Venezuela that is pledged as collateral after the effective date of this order, including accounts receivable; and

(iii) the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela of any equity interest in any entity in which the Government of Venezuela has a 50 percent or greater ownership interest.

The prohibition applies to US persons and all transactions within the United States. The prohibition extends to "financing" or "any other dealings" with regards to all such transactions.

Addition of further Venezuelan individuals to OFAC SDN list

Furthermore, on 18 May 2018, the United States Office Of Foreign Assets Control (OFAC) added four further individuals to its "Special Designated Nationals" (SDN) list.

The effect of these designations is that the assets of the designated individuals concerned are blocked, and US persons are generally prohibited from dealing with them.   

The relevant individuals are detailed in the attachment to this web alert, which is taken directly from the US Treasury website.

Comment

The latest sanctions against Venezuela provide further evidence of the Trump Administration's combative approach to the Maduro regime in Venezuela, and its willingness to impose further economic sanctions against this regime,  which it considers, in the words of the Executive Order, to be responsible for a "deepening humanitarian and public health crisis" at the expense of the Venezuelan people. 

While the latest Executive Order mainly targets financial transactions, the latest sanctions and addition of further Venezuelan individuals to the SDN list serve as a reminder of substantial sanctions risk involved in Venezuelan-linked trade. 

These sanctions follows on from the sanctions imposed against Venezuela in April 2018, which were reported on by the club here.

Accordingly, the club strongly encourages its members to carry out necessary commercial due diligence in respect of Venezuelan-trade, to ensure that the relevant trade is not sanctioned.  

The club is able to provide general guidance on sanctions-related queries to assist Members.  It is also able to assist with recommending expert sanctions lawyers to advise Members on sanctions, if this is required.