OFAC Clarifies, and Further Complicates, Sanctions on Venezuela, PdVSA

February 04, 2019

On February 1, 2019, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued guidance in the form of Frequently Asked Questions (“FAQs”) relating to sanctions imposed on January 28, 2019 against Venezuela and Petróleos de Venezuela SA (“PdVSA”). Many of the FAQs clarify how U.S. persons may properly utilize the general licenses (“GLs”) announced January 28. Later the same day, however, OFAC issued two amended GLs that further restricted how U.S. persons can deal in Government of Venezuela (“Ven”) bonds but also somewhat expanded the prior authorization that covered trading in PdVSA bonds. The upshot is that Ven bonds and PdVSA bonds are now effectively subject to the same restrictions, although the former are not treated as blocked property by OFAC. Our coverage of the sanctions imposed on January 28 is available here.

Read "OFAC Clarifies, and Further Complicates, Sanctions on Venezuela, PdVSA."

Subscribe to Dechert Updates