OFAC amends Venezuela Sanctions Regulations

The Office of Foreign Assets Control of the US Department of the Treasury has amended the Venezuela Sanctions Regulations, 31 CFR part 591.  The amendments include a new general license authorizing some US government activities, and incorporate additional Executive Orders, in addition to a new interpretive provision.

The Venezuela Sanctions Regulations were issued on July 10, 2015 to implement the Venezuela Defense of Human Rights and Civil Society Act of 2014, and Executive Order 13692.  Since then, six additional Venezuela-related Executive Orders have been issued:  
  • Executive Order 13808 of August 24, 2017 (“Imposing Additional Sanctions With Respect to the Situation in Venezuela”) (82 FR 41155, August 29, 2017); 
  • Executive Order 13827 of March 19, 2018 (“Taking Additional Steps to Address the Situation in Venezuela”) (83 FR 12469, March 21, 2018); 
  • Executive Order 13835 of May 21, 2018 (“Prohibiting Certain Additional Transactions With Respect to Venezuela”) (83 FR 24001, May 24, 2018); 
  • Executive Order 13850 of November 1, 2018 (“Blocking Property of Additional Persons Contributing to the Situation in Venezuela”) (83 FR 55243, November 2, 2018); 
  • Executive Order 13857 of January 25, 2019 (“Taking Additional Steps To Address the National Emergency With Respect to Venezuela”) (84 FR 509, January 30, 2019), and;
  • Executive Order 13884 of August 5, 2019 (“Blocking Property of the Government of Venezuela”) (84 FR 38843, August 7, 2019).
The amendments expand existing § 591.201 to include all transactions prohibited pursuant to Executive Order 13692.  OFAC has also incorporated a general license into subpart E of the Regulations (§ 591.509), authorizing the US government to engage in certain Venezuela-related activities.  The new interpretive provision clarifies that entering into a settlement or enforcing a lien, judgment or decree that alters, transfers or affects property blocked pursuant to § 591.201 is prohibited unless specifically authorized by an OFAC license.

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