The US imposes only primary sanctions in relation to Venezuela.
Debt and equity of the Venezuelan government. Executive Orders 13,808 and 13,835 prohibit certain transactions by US persons or within the United States involving debt and equity of the Government of Venezuela, payment of dividends to the Government of Venezuela, and securities held by the Government of Venezuela.1
Executive Order 13808 prohibits transactions related to:
- certain new debt of the Government of Venezuela, including Petroleos de Venezuela, S.A. (PdVSA); and
- certain bonds, dividend payments, and securities of the Government of Venezuela.
OFAC has issued five general licenses authorizing certain activities by US persons that would otherwise be prohibited by the Executive Order. The general licenses authorize certain transactions involving CITGO Holding, Inc., all transactions related to the provision of financing for, and other dealings in certain bonds and new debt transactions related to the exportation or reexportation of agricultural commodities, medicine, medical devices, or replacement parts and components, and certain transactions related to the PdVSA 2020 8.5% bond.
Executive Order 13,835 prohibits all transactions related to, provision of financing for, and other dealings in the following by a US person or within the United States:
- the purchase of any debt owed to the Government of Venezuela, including accounts receivable;
- any debt owed to the Government of Venezuela that is pledged as collateral after
January 9, 2018, including accounts receivable; and
- 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% or greater ownership interest.
Cybercurrency. Executive Order 13,827 prohibits all transactions by a US person or within the United States related to, provision of financing for, and other dealings in any digital currency, digital coin, or digital token that was issued by, for, or on behalf of the Government of Venezuela on or after January 9, 2018.2
1 Exec. Order No. 13,808, 82 Fed. Reg. 41155 (Aug. 24, 2017); Exec. Order No. 13,835, 83 Fed. Reg. 24001 (May 21, 2018).
2 Exec. Order No. 13,827, 83 Fed. Reg. 12469 (Mar. 19, 2018).