On June 18, 2020, the US Department of the Treasury’s Office of Foreign Assets Control issued general license 37, pursuant to the Venezuela Sanctions Regulations, 31 CFR Part 591, to enable US companies to wind down business deals and transactions with two shipping companies – Delos Voyager Shipping LTD and Romina Maritime Co. Inc. and certain vessels associated with each company. OFAC designated both companies and vessels, as well as any entity that owns a direct or indirect 50 percent or greater interest in these companies. As a result, US entities are prohibited from entering new commercial contracts or processing any transactions through a US financial institution, with the designated companies and vessels after July 21, 2020, by Executive Order 13850 of November 1, 2018, as amended by E.O. 13857 of January 25, 2019.
In addition, OFAC updated its Frequently Asked Questions (FAQ) to clarify the terms of its Counter Terrorism Sanctions made pursuant to Executive Order 13224, as amended. FAQ 812 states that US entities are prohibited from engaging in any transaction involving information or informational materials including artwork that belongs to a person designated as Specially Designated Global Terrorists (SDGTs) or otherwise blocked pursuant to E.O. 13224, with certain exemptions available for humanitarian communications and donations available under the International Emergency Economic Powers Act (IEEPA). FAQ 813 specifically addresses members of the art community reiterating the prohibition on transactions involving art work and urging US individuals and entities to develop a risk-based compliance program to avoid sanctions violations. Finally, FAQ 814 advises anyone who may be in possession of prohibited artwork, that they are prohibited from selling the artwork, and they have 10 business days to report it OFAC, pursuant to 31 CFR section 501.603.