The US imposes only primary sanctions in relation to Venezuela.

Executive Order 13884 blocks all property and interests in property of the Government of Venezuela.1

  • The Executive Order also blocks the property of those deemed to have materially assisted any of the persons whose property was blocked due to the order or who are owned or controlled, or acted or purported to act on behalf directly or indirectly of any of the persons whose property was blocked due to the order.
  • Transactions are authorized with certain individuals who meet the definition of Government of Venezuela provided that the individuals are United States citizens or permanent residents and former employees of he Government of Venezuela.

Executive Order 13850 blocks the property of additional persons who may be contributing to the situation in Venezuela.2

  • This includes those operating in the gold sector of the Venezuelan economy, or any other sector as determined by the Secretary of the Treasury.
  • On January 28, 2019, OFAC designated the Venezuelan state oil company, Petróleos de Venezuela, S.A. (“PDVSA”) pursuant to this authority.

As of May 2021, there are 26 active general licenses issued by OFAC that authorize certain activities by US persons that would otherwise be prohibited by the Executive Orders in the Venezuela-related Sanctions program.  The general licenses authorize, among other things:

  • Certain transactions involving PDVH Holding, Inc. and CITGO Holding, Inc., and their subsidiaries.
  • Transactions involving blocked entities for certain listed US companies with specific significant operations involving Venezuela in the energy and banking sectors.
  • Transactions involving the Government of Venezuela in support of humanitarian projects.

Cybercurrency.  Executive Order 13827 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, 2018.3

1 Exec. Order No. 13884, 84 Fed. Reg. 152 (Aug. 6, 2019).

Exec. Order No. 13850, 83 Fed. Reg. 213 (November 2, 2018).

3 Exec. Order No. 13827, 83 Fed. Reg. 12469 (Mar. 19, 2018).

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