On April 17, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) made several updates to the sanctions regime against Venezuela, including designating the Central Bank of Venezuela and a Venezuelan official as Specially Designated Nationals (“SDNs”), adding two new general licenses, amending five prior general licenses, and issuing one Frequently Asked Question (“FAQ”). The updates primarily relate to the designation of the Central Bank of Venezuela, and winding down, or authorizing current agreements with the bank.
With respect to the Venezuela sanctions regime, OFAC added one individual to the SDN list pursuant to Executive Order 13692, along with one entity, the Central Bank of Venezuela, pursuant to Executive Order 13850. OFAC also added two new general licenses related to the designation of the Central Bank of Venezuela, and amended five others. Specifically, OFAC added General License 19 authorizing activities relate to the wind down of operations or existing contracts involving Central Bank of Venezuela and General License 20 authorizing official activities of certain international organizations involving Central Bank of Venezuela. OFAC also amended a number of Venezuela-related general licenses primarily to add the Central Bank of Venezuela to certain existing authorizations.
At the same time, OFAC also made additions to sanctions involving Nicaragua. Specifically, it designated one individual, Laureano Ortega, and one entity, Banco Corporative SA (a.k.a. Banco Nacional, Banco National, Bancorp, or National Bank), as SDNs.